Case Summary (G.R. No. 248729)
Petitioner and Respondent
Petitioner: Joel C. Javarez
Respondent: People of the Philippines
Key Dates
February 7, 2008 – Alleged incidents of physical abuse
April 10, 2014 – Trial Court conviction and sentencing
September 14, 2018 – Court of Appeals affirmance and modification of damages
September 3, 2020 – Supreme Court decision
Applicable Law
1987 Philippine Constitution (post-1990 decision)
Republic Act No. 7610, Section 10(a) and Section 31(e)
Revised Penal Code, Article 266(2) on slight physical injuries
Civil Code, Article 2219(1) on moral damages
Factual Background
On the morning of February 7, 2008, during a review class for the National Admission Test, BBB asked a classmate for “pop rice,” sparking a fight. Petitioner intervened and struck BBB’s left cheek with a broomstick handle. In the afternoon session, AAA observed a dispute over food; petitioner approached and pushed AAA in the chest, causing him to fall face-first. Both minors reported pain and were examined at Brooke’s Point Hospital, where medico-legal certificates documented tenderness in AAA’s chest area and abrasions and hematoma on BBB’s face and ear.
Trial Court Proceedings and Ruling
Petitioner pleaded not guilty. The trial court credited the minors’ direct and consistent testimonies, corroborated by medical findings, and found no ill motive for their accusations. On April 10, 2014, it convicted petitioner of two counts of child abuse under RA 7610, imposing maximum penalties under Section 31(e) and awarding P10,000 civil indemnity and P10,000 damages to each child.
Appeal to the Court of Appeals
Petitioner challenged the credibility of prosecution witnesses and offered alternative explanations (a cockfight injury). The Court of Appeals, in a September 14, 2018 decision, upheld the convictions under Section 10(a), Article VI of RA 7610, clarified that proof of prejudice to the child is not required when liability is based on any act of abuse, and increased moral and exemplary damages to P20,000 each. Reconsideration was denied on June 20, 2019.
Issues on Supreme Court Review
Whether petitioner’s acts fell within RA 7610’s definition of child abuse requiring specific intent to debase, degrade, or demean a child’s intrinsic dignity, and if not, whether the acts qualify as slight physical injuries under the Revised Penal Code.
SC’s Analysis on RA 7610 Liability
Child abuse under RA 7610 Section 10(a) demands proof of actual intent to debase, degrade, or demean a child’s dignity. Citing Bongalon v. People and Jabalde y Jamandron v. People, the Court held that petitioner’s interventions aimed solely at halting student fights, without any demonstrable intent to humiliate AAA or BBB. Consequently, petitioner cannot be held liable under RA 7610 for either incident.
SC’s Analysis on Revised Penal Code Liability
Under RPC Article 266(2), slight physical injuries require malicious intent to inflict physical harm. BBB’s uncontradicted testimony and medical evidence of abrasions and hematoma established that petitioner maliciously struck him with a broomstick. There was no proof of incapacitation or need for medical attendance beyond docu
Case Syllabus (G.R. No. 248729)
Background and Facts
- Joel C. Javarez, a public elementary school teacher at Iraray Elementary School in Sofronio Española, Palawan, faced two separate incidents of alleged physical abuse on February 7, 2008.
- In the morning session, third-grader BBB repeatedly asked a classmate for rice pop, was refused, and fought; petitioner intervened by striking BBB’s face with a broomstick.
- In the afternoon session, ten-year-old AAA returned from a break to see classmates fighting; petitioner approached and pushed AAA in the chest, causing him to fall face-down.
- Both minors immediately reported the incidents to AAA’s mother (XXX) and subsequently to school authorities; upon finding no relief, a complaint was filed with the Department of Social Welfare and Development.
- Medical‐legal examinations showed AAA suffered chest pain and tenderness consistent with pushing, and BBB sustained left cheek abrasions and ear hematoma consistent with contact with a sharp object or broomstick.
Charges and Plea
- Criminal Case No. 24935: Charged under Section 10(a) in relation to Section 31(e) of RA 7610 for willful, unlawful physical abuse of AAA, a ten-year-old minor, by pushing him without provocation.
- Criminal Case No. 24936: Charged under the same provisions for willful, unlawful physical abuse of BBB, a nine-year-old minor, by hitting him in the face with a broomstick after a schoolyard dispute.
- Petitioner pleaded “not guilty” to both Informations; the cases were tried jointly.
Prosecution Evidence
- Direct testimony of AAA and BBB describing petitioner’s unprovoked push and broomstick blow, respectively.
- Medical‐legal certificates corroborating injury patterns: chest/sternal tenderness for AAA; cheek abrasions and ear hematoma for BBB.
- Affidavits executed by both minors at the police station detailing the incidents.
- DSWD complaint records and hospital examination reports substantiating immediate reporting and physical findings.
Defense Evidence
- Petitioner’s testimony asserting he stepped in to separate fighting pupils and r