Case Summary (G.R. No. 255466)
Key Dates and Applicable Law
The decision under review stems from the March 3, 2020 ruling of the Court of Appeals in CA-G.R. CR No. 41234, which upheld the initial findings of the Regional Trial Court (RTC) from December 21, 2017. The applicable laws in this case include Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act) and Republic Act No. 7610 (Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act).
Criminal Charges and Allegations
Petitioner faced two separate charges:
- In Criminal Case No. 12-CR-8989, he was charged with psychological violence against CCC, as defined by Section 5(i) of Republic Act No. 9262.
- In Criminal Case No. 12-CR-8990, he was charged with Acts of Lasciviousness against AAA, which fell under Section 5(b) of Republic Act No. 7610 and Article 336 of the Revised Penal Code.
Summary of Events Leading to Charges
The charges stemmed from a series of abusive behaviors exhibited by the petitioner towards CCC, including physical and verbal abuse. CCC testified about the psychological and emotional distress she suffered due to petitioner’s actions, which included threats of violence and surveillance that instilled fear in her. Additionally, allegations of sexual abuse against AAA surfaced when she disclosed incidents of inappropriate touching to her mother, CCC.
Trial Proceedings and Findings
Upon arraignment, the petitioner pleaded not guilty to both charges, leading to a trial where CCC provided detailed testimony regarding the abuse. The RTC found sufficient evidence to convict the petitioner for both psychological violence and acts of lasciviousness based on CCC and AAA's accounts as well as medical evaluations indicating injury.
Ruling and Sentencing by the RTC
The RTC sentenced the petitioner to:
- An indeterminate penalty of 6 months and 1 day to 6 years of imprisonment for psychological violence, along with a fine of Php 200,000 and mandatory counseling.
- An indeterminate penalty of 12 years and 1 day to 17 years for acts of lasciviousness, plus civil indemnities totaling Php 65,000 to AAA.
Ruling and Modifications by the Court of Appeals
The Court of Appeals affirmed the RTC's decision but modified the penalties:
- For psychological violence: 4 years and 2 months to 8 years was imposed.
- For acts of lasciviousness: the penalty range adjusted to 12 years and 10 months to 15 years, with a total of Php 150,000 in damages awarded to AAA.
Petitioner’s Arguments in Appeal
The petitioner argued that the prosecution failed to demonstrate the requisite emotional anguish CCC suffered, claiming that her testimony lacked specific details of her emotional distress. Additionally, he contested that elements necessary to prove the charges, particularly concerning AAA's age and the nature of the acts constituted as lascivious conduct, were inadequately established by the evidence.
Legal Analysis of the Issues Raised
The Supreme Court noted that in a petition for review, it does not reevaluate factual findings of the lower courts unless there is clear evidence of overlooked details. It stated that emotional or psychological distress can be established through the victim’s testimony alone, as psychological violence does not demand proof of psychological illness but merely the existence of mental anguish.
Determination of Convictions
The
Case Syllabus (G.R. No. 255466)
Parties and Case Background
- Petitioner BBB255466 filed a Petition for Review on Certiorari contesting his conviction by the Court of Appeals (CA) and the Regional Trial Court (RTC) of Benguet in Criminal Case Nos. 12-CR-8989 and 12-CR-8990.
- Criminal Case No. 12-CR-8989 charged petitioner with psychological violence against his common-law partner CCC under Section 5(i) of Republic Act (RA) No. 9262.
- Criminal Case No. 12-CR-8990 charged petitioner with acts of lasciviousness against his daughter AAA under Article 336 of the Revised Penal Code in relation to RA 7610 Section 5(b).
- Petitioner pleaded "Not Guilty" to both charges.
Facts of the Case
- Petitioner and CCC were common-law partners since 2003 and have a child, AAA, born on January 12, 2005.
- CCC testified to repeated physical and verbal abuse by petitioner, including threats to kill her, chasing her with a bolo, and attempting to throw a 50-kilogram LPG tank at her.
- Petitioner repeatedly harassed CCC at her boarding house in Benguet, sometimes forcibly entering and using abusive language.
- AAA, then about 7 years old, testified that petitioner sexually abused her by making her hold his penis and by touching her vagina.
- Medical examination of AAA revealed swelling on her cheek possibly caused by trauma.
- Petitioner did not present any evidence or legal representation during trial.
Trial Court Decision
- RTC found petitioner guilty beyond reasonable doubt of psychological violence under Section 5(i) of RA 9262 and acts of lasciviousness under Section 5(b) of RA 7610.
- Imposed indeterminate penalties with prison terms ranging from 6 months to 8 years for psychological violence and 12 years 1 day to 17 years for acts of lasciviousness.
- Ordered petitioner to pay fines (PHP 200,000 for psychological violence) and damages (PHP 30,000 moral damages, PHP 20,000 civil indemnity, PHP 15,000 exemplary damages for AAA).
- Directed petitioner to undergo psychological counseling or psychiatric treatment.
Court of Appeals Ruling
- CA affirmed RTC's guilt findings but modified the penalty terms for both counts.
- Psychological violence penalty modified to 4 years 2 months to 8 years 1 day prision correctional/mayor, with a fine of PHP 200,000.
- Acts of lasciviousness penalty modified to an indeterminate term of 12 years 10 months 21 days to 15 years 6 months 20 days reclusion temporal; damages increased to PHP 50,000 each for civil indemnity, moral damages, and exemplary damages; and a fine of PHP 15,000.
- Ordered interest on damages at 6% per annum from finality date.
- Denied petitioner’s motion for reconsideration confirming credibility of testimonies and findings.
Issues Presented
- Whether the CA erred in affirming petitioner’s conviction for psychological violence under Section 5(i) of RA 9262 against CCC.
- Whether the CA erred in affirming petitioner’s conviction for violation of Section 5(b) of RA 7610 for acts of lasciviousness against AAA.