Case Digest (G.R. No. 268457) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves petitioner XXX who was charged with three counts of child abuse under Section 10(a) of Republic Act No. 7610, the Special Protection of Children Against Abuse, Exploitation and Discrimination Act. The charges arose from incidents occurring in the Municipality of xxxxxxxxxxx on September 22, 2017, and February 21, 2018. XXX was accused of physically abusing his two minor children, AAA (12 years old) and BBB (10 years old), by hitting, kicking, pulling hair, and using implements such as a wooden rod embedded with a nail and a dustpan, causing them physical injuries and debasing their intrinsic human dignity. XXX pleaded not guilty. The Regional Trial Court (RTC) found XXX guilty beyond reasonable doubt and sentenced him to indeterminate terms of imprisonment and awarded moral damages to the victims. The Court of Appeals (CA) affirmed with modification the RTC's decision and sentencing, reducing the moral damages but adding exemplary and temperate damages and a fi... Case Digest (G.R. No. 268457) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charges Against XXX
- XXX was charged with three separate counts of child abuse under Section 10(a) of Republic Act No. 7610, involving physical abuse against his minor children, BBB (10 years old) and AAA (12 years old).
- Criminal Case No. 4556-M-2018: On or about February 21, 2018, XXX assaulted his son, BBB, with a dustpan causing physical injuries, while cursing him.
- Criminal Case No. 4557-M-2018: On or about February 21, 2018, XXX assaulted his daughter, AAA, by pulling her hair, kicking, and cursing her, causing physical injuries.
- Criminal Case No. 4558-M-2018: On or about September 22, 2017, XXX hit AAA with a wooden beater embedded with a nail causing physical injuries.
- Trial Proceedings
- XXX pleaded not guilty initially.
- Prosecution presented testimonies of AAA and BBB, who described the incidents of abuse.
- AAA testified that on September 22, 2017, XXX struck her multiple times on the back, right arm, and right thigh with a wooden rod embedded with a nail, while cursing her for not eating lunch.
- On February 21, 2018, XXX confronted AAA and BBB over missing money, threw a coin bank at them, and then physically assaulted them using a dustpan and by pulling AAA’s hair.
- Medical examinations confirmed the physical injuries sustained by AAA and BBB.
- Defense Testimony
- XXX denied hitting AAA with a wooden rod but admitted to spanking his children with a dustpan for discipline.
- He admitted frustration due to financial difficulties and his separation from his wife, CCC.
- XXX claimed his children fabricated the accusations to gain support.
- RTC Decision
- Found XXX guilty beyond reasonable doubt of three counts of child abuse.
- Credited the testimonies of AAA and BBB as truthful, describing the accused's acts as excessive and abusive discipline.
- Sentenced XXX to indeterminate penalties ranging from prision correccional to prision mayor and ordered payment of P50,000 as moral damages to each victim.
- CA Decision
- Affirmed the RTC’s conviction with modifications.
- Reduced moral damages to PHP 20,000 each and added amounts for exemplary and temperate damages, plus fines of PHP 15,000 for each count.
- Cancelled petitioner’s bail bond and ordered issuance of warrant of arrest.
- Supreme Court Review
- The Petitioner sought acquittal, arguing lack of specific intent to debase, degrade or demean the children’s dignity.
- The People argued the acts and circumstances established the necessary intent for child abuse.
Issues:
- Whether XXX was proven guilty beyond reasonable doubt of three counts of child abuse punishable under Section 10(a) of Republic Act No. 7610.
- Whether the acts committed by XXX possessed the specific intent to debase, degrade and demean the intrinsic worth and dignity of the minor children.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)