Case Digest (G.R. No. 268457)
Facts:
XXX v. People of the Philippines, G.R. No. 268457, July 22, 2024, the Supreme Court Second Division, Lopez, J., writing for the Court.In three separate Informations filed in the Regional Trial Court (RTC), XXX was charged with three counts of child abuse under Section 10(a) of Republic Act No. 7610 for physically assaulting his children: Criminal Case Nos. 4556-M-2018 (against his then‑10‑year‑old son BBB), 4557‑M‑2018 (against his then‑12‑year‑old daughter AAA), and 4558‑M‑2018 (also against AAA for an earlier incident). Upon arraignment, petitioner pleaded not guilty and the cases proceeded to trial.
At trial the prosecution presented testimony from AAA and BBB, who related two separate episodes: on September 22, 2017, AAA said petitioner struck her with a wooden rod embedded with a nail, causing pain and contusions; and on February 21, 2018, both children testified that petitioner hurled a coin bank, forced them upstairs, pulled AAA’s hair, kicked and hit her head, and struck BBB repeatedly with the handle of a dustpan. Medical certificates corroborated injuries and treatment on February 23, 2018. Petitioner testified as sole defense witness, admitting he spanked his children (including with a dustpan) but claiming the acts were disciplinary and provoked, denying the severity alleged and insisting he provided support for them.
The RTC (Branch 9) found petitioner guilty beyond reasonable doubt of three counts under Section 10(a), giving credence to the children's straightforward testimonies and the medical evidence and finding petitioner’s account inconsistent; it imposed indeterminate sentences and awarded PHP 50,000 moral damages to each complainant in each case. Petitioner appealed to the Court of Appeals (CA).
The CA, in CA‑G.R. CR No. 45863, affirmed the convictions but modified the monetary awards: it set moral damages at PHP 20,000, and added exemplary and temperate damages of PHP 20,000 each plus a PHP 15,000 fine per count; it ordered interest and cancelled petitioner’s bail. Petitioner’s motion f...(Subscriber-Only)
Issues:
- Was petitioner XXX’s guilt for child abuse under Section 10(a) of Republic Act No. 7610 proven beyond reasonable dou...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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