Case Digest (G.R. No. 261049)
Facts:
XXX261049 v. People of the Philippines, G.R. No. 261049, June 26, 2023, Supreme Court Second Division, Lopez, M., J., writing for the Court. The petition assails the Court of Appeals Decision dated June 25, 2021 and Resolution dated May 16, 2022 in CA‑G.R. CR No. 43881, which affirmed the Regional Trial Court Joint Decision dated February 8, 2019 convicting petitioner for violations of Section 4(a) of Republic Act No. 9995 (Anti‑Photo and Video Voyeurism Act of 2009).The accused, identified in the record by initials XXX261049 (petitioner), was charged in four Informations (Crim. Nos. 18882–18885) with secretly taking video/photographic images of his nieces and a cousin—AAA261049, BBB261049, CCC261049, and DDD261049—while they were bathing, without their consent and under circumstances where they had a reasonable expectation of privacy. The prosecution’s witnesses included the three sisters and their cousin, plus a construction worker, Richard; the defense presented the accused’s denial.
At trial the prosecution established that AAA discovered a Blackberry phone hidden in a Safeguard soap box in the bathroom with its video running; she said she saw a clip showing her uncle setting up the phone, then deleted that clip in alarm but copied stills and snippets of other nude videos to her own phone and later to a DVD‑R and printed copies. Witnesses testified that only petitioner used that type of phone in the household, that petitioner had used the bathroom immediately before AAA, and that the renovation workers had no access to the bathroom. The prosecution introduced the printed stills, the DVD‑R and the soap box as exhibits.
The RTC (Branch xx) rendered a Joint Decision (Feb. 8, 2019) finding petitioner guilty in Criminal Cases Nos. 18882–18884 and acquitting him in No. 18885 for lack of any photo/video of DDD. The CA affirmed in a Decision dated June 25, 2021 and denied petitioner’s motion for reconsideration in a Resolution dated May 16, 2022. Petitioner filed a Petition...(Pro-only)
Issues:
- Was petitioner XXX261049’s guilt for violation of Section 4(a), R.A. No. 9995 proven beyond reasonable doub...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)