G.R. No. 261049 - XXX61049 vs. People

XXX261049 was charged in four criminal cases (Criminal Cases Nos. 18882-18885) for violating Section 4(a) of Republic Act No. 9995, the "Anti-Photo and Video Voyeurism Act of 2009."
The charges involved unlawfully taking video coverage of four victims (AAA261049, BBB261049, CCC261049, and DDD261049), capturing their private areas without consent while they were bathing, under circumstances where they had a reasonable expectation of privacy.

The victims are three sisters and one cousin living in the same house.
XXX261049 is their uncle who frequently visited the house during renovation works.
Richard Castillo and others were construction workers on-site but had no access to the bathroom.

On October 11, 2016, AAA261049 noticed her uncle entering the bathroom, after which the uncle came out and she prepared to bathe.
She saw a small light through a small hole in a Safeguard soap box on a shelf and found a Blackberry phone inside with the video feature recording for about nine minutes.
AAA261049 recognized it as XXX261049's phone, placed so its camera captured the bathroom area.
Upon reviewing, she saw a video of her uncle setting up the phone in the bathroom and multiple nude videos of herself and the other victims while bathing.
Initially, she deleted the videos but had the foresight to use her own phone to capture stills and snippets of the videos on XXX261049's phone.
She replaced the phone in the same concealed manner and informed her aunt, mother, and the other victims.
The victims confronted XXX261049, who denied the accusations but offered his phone for inspection, which was refused since the videos were already copied and deleted.
The victims reported the incident to the barangay the following day.

AAA261049, BBB261049, CCC261049, and DDD261049 testified that they saw the nude videos stills taken from the phone.
Richard Castillo confirmed no access to the bathroom by other workers.
It was proven that only XXX261049 had the type of phone used.
Physical evidence included printed copies of the images, a DVD containing the copied materials, and the Safeguard soap box used as concealment.

Denied the acts and claimed to have lost a similar phone three months before the incident.
Alleged the nieces fabricated the story due to personal dislike.

RTC convicted XXX261049 in cases 18882-18884 based on credible testimonies and evidence, acquitted in 18885 due to lack of direct evidence involving DDD261049.
CA affirmed the RTC rulings and denied motion for reconsideration.

XXX261049 contended the evidence was purely circumstantial and insufficient.
Argued presence of other potential suspects (construction workers).
Questioned the credibility of witness AAA261049 for deleting critical video evidence.
Denied ownership of the phone and argued the act was improbable because of victims' proximity.

Whether XXX261049's guilt for violating Section 4(a) of RA No. 9995 was proven beyond reasonable doubt.