Case Summary (G.R. No. 137377)
Applicable Law
The case primarily revolves around violations of Republic Act No. 7610, known as the Special Protection of Children Against Abuse, Exploitation and Discrimination Act, specifically Section 5(b), which relates to sexual abuse through lascivious conduct.
Summary of Facts
In the initial charge, Capueta was accused of child abuse under Section 10(a) of RA 7610 for allegedly committing acts of child abuse by inappropriately touching AAA. During trial, eyewitness testimonies from AAA, her mother BBB, and Barangay Tanod Arnel Cariaso confirmed the events wherein Capueta allegedly lifted AAA's skirt and touched her inappropriately. After confronting Capueta, BBB reported the incident to the authorities following Capueta's denial and threats.
Ruling of the Regional Trial Court
The Regional Trial Court (RTC) ultimately found Capueta guilty beyond reasonable doubt of violating Section 5(b) of RA 7610, rather than the initially charged Section 10(a). The RTC's decision highlighted the credibility of AAA's testimony and the immediate reporting of the incident as factors that corroborated the misconduct. As a result, Capueta was sentenced to a substantial prison term and financial penalties, including civil and moral damages.
Ruling of the Court of Appeals
The Court of Appeals (CA) affirmed the RTC's judgment, emphasizing the adequate proof of the elements of lascivious conduct and AAA's minor status at the time of the offense. The CA noted the consistency of AAA's statements regarding the incident and dismissed Capueta's defense as insufficient, leading to the upholding of the conviction while modifying the parameters of the sentence.
Legal Issues Raised
Capueta contested the ruling, citing a lack of demonstrated criminal intent and an assertion that the information filed did not sufficiently allege exploitation under Section 5(b). He argued that this omission violated his constitutional right to be informed about the charges against him.
The Court's Decision
The court rejected Capueta's arguments, elucidating that the prosecution had successfully established the elements of sexual abuse as defined under the RA 7610 and the Revised Penal Code. The court underscored that the definition of lascivious conduct includes the intentional inappropriate touching of a minor. The court also clarified that intimidation is sufficiently established when the victim's age and vulnerability are considered, negating Ca
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Facts of the Case
- Jaime Capueta y Ataday (petitioner) was charged with violation of Section 10(a) of Republic Act No. 7610 (RA 7610), known as the Special Protection of Children Against Abuse, Exploitation and Discrimination Act.
- The charge, filed on November 16, 2008, alleged that petitioner committed acts of child abuse by touching the legs, arms, and private organ of AAA, a 6-year-old minor, thereby degrading her dignity and impairing her emotional and psychological development.
- AAA was playing at the house owned by petitioner’s sister when petitioner allegedly lifted her skirt and touched her vulva and thigh areas.
- AAA ran home crying and reported the incident to her mother, BBB, who confronted petitioner. Petitioner denied wrongdoing and threatened BBB.
- BBB brought AAA to the barangay hall to report the abuse; barangay officials (Barangay Tanod Arnel Cariaso and others) apprehended petitioner and brought him for medical examination before turning him over to police authorities.
- Prosecution presented testimonies of AAA, BBB, Barangay Tanod Cariaso, and stipulated the testimony of the investigating police officer, PO2 Rhona Mea Padojinog.
- Documentary evidence included sworn statements by AAA, BBB, and Tanod Cariaso, AAA’s birth certificate, and the investigation report.
- Petitioner denied the charges, claiming he accidentally fell down the stairs near AAA without lewd intent and that BBB demanded a ₱50,000 settlement which he refused, prompting the complaint.
Issue Presented
- Whether the Court of Appeals committed grave error in affirming the trial court’s finding that petitioner is guilty beyond reasonable doubt of Acts of Lasciviousness in relation to Section 5(b), Article III of RA 7610.
Trial Court Decision
- The RTC found petitioner guilty beyond reasonable doubt of violation of Section 5(b), Article III of RA 7610, reclassifying the charge to sexual abuse through lascivious conduct under RA 7610 and Article 336 of the Revised Penal Code (RPC).
- The RTC sentenced petitioner to twelve (12) years, ten (10) months, and twenty-one (21) days to fifteen (15) years, six (6) months, and twenty (20) days of reclusion temporal.
- Civil indemnity of ₱20,000, moral damages of ₱15,000, and fine of ₱15,000 were awarded to the victim.
- The RTC credited AAA’s testimony as credible, consistent, and unshaken despite her young age, noting her immediate report and her mother’s confrontation, while dismissing petitioner’s defense as weak and unconvincing.
Court of Appeals Ruling
- The CA affirmed the RTC judgment, finding the prosecution sufficiently proved the elements of acts of lasciviousness under Article 336 RPC and lascivious conduct under Section 5(b) of RA 7610.
- Affirmed AAA’s credibility due to consistent and positive identification of petitioner as her