Title
BBB255466 vs. People
Case
G.R. No. 255466
Decision Date
Nov 27, 2024
Petitioner BBB255466 was found guilty of psychological violence against his common-law partner and acts of lasciviousness against his daughter. The court affirmed the decisions of the lower courts with modified penalties.

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:

  1. 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.
  2. 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:

  1. 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.
  2. 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:

  1. For psychological violence: 4 years and 2 months to 8 years was imposed.
  2. 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

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