Title
Patulot y Galia vs. People
Case
G.R. No. 235071
Decision Date
Jan 7, 2019
Petitioner convicted for child abuse under R.A. No. 7610 after pouring boiling oil, injuring children; intent irrelevant, penalties upheld with damages.

Case Summary (G.R. No. 235071)

Petitioner and Respondent

Petitioner: Evangeline Patulot (defendant convicted below). Respondent: People of the Philippines (prosecution). The petition is a Rule 45 petition for review on certiorari seeking reversal of the CA’s affirmation of petitioner’s conviction for two counts of child abuse under Republic Act No. 7610.

Key Dates and Procedural Posture

Incident: November 14, 2012. RTC conviction: November 19, 2014 (found guilty of two counts of child abuse and imposed indeterminate penalties, damages, and fines). CA decision: July 13, 2017 (affirmed conviction, modified penalties). Petitioner filed the present Supreme Court petition on January 4, 2018. (The Supreme Court’s disposition affirms the CA decision with modification as to interest on damages.)

Applicable Law and Legal Definitions

Primary statute: Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination), in particular Section 3(b) (definitions including physical abuse) and Section 10(a) (penalty provision for other acts of child abuse, cruelty or exploitation, punishable by prision mayor in its minimum period). Relevant implementing definition from the Rules and Regulations on Reporting and Investigation of Child Abuse Cases that defines “child abuse” and “physical injury” (including burns). Penal Code provisions invoked: Article 49 (penalty to be imposed where the felony committed is different from that intended) and Article 265 (less serious physical injuries). Constitutional reference: 1987 Constitution, Article XV, Section 3, paragraph 2 (State duty to protect children), which underpins the protective purpose of R.A. No. 7610.

Criminal Charges and Information

Petitioner was charged in two separate Informations alleging willful, unlawful and felonious acts of child abuse under R.A. No. 7610 for throwing boiling oil on two minor victims (AAA, age three; BBB, age two months) on or about November 14, 2012 in Taguig City, thereby inflicting physical injuries prejudicial to the children’s normal growth and development. During arraignment petitioner pleaded not guilty.

Prosecution Evidence and Factual Findings at Trial

The prosecution presented testimony from CCC (mother), DDD (father), and Dr. Vitales, and offered documentary evidence including Sinumpaang Salaysay, medico-legal certificates, birth certificates, photographs, and medical receipts. CCC recounted that petitioner unexpectedly poured hot cooking oil from a casserole intending to strike CCC; AAA and BBB, nearby, were also hit and injured. Neighbors transported the children to a polyclinic and later to Pateros-Taguig District Hospital; CCC was also treated and executed a statement at the Taguig Police Station. Dr. Vitales testified that the children’s injuries would heal on average in thirty days; the trial court found visible scars likely to remain and relied on these findings in concluding the acts were prejudicial to the children’s development.

Petitioner’s Defense

Petitioner testified in her own behalf, denying intent to harm the children and stating that she intended to pour the oil on CCC alone following an earlier physical and verbal altercation. Petitioner asserted that the oil accidentally hit AAA and BBB, and argued she should be liable, if at all, only for physical injuries (less serious physical injuries) and not for child abuse under R.A. No. 7610; she further invoked Article 49 of the Revised Penal Code regarding error in personae and argued for application of the penalty for the intended offense (physical injuries) in its maximum period.

RTC Decision and Rationale

The RTC found petitioner guilty beyond reasonable doubt of two counts of child abuse under R.A. No. 7610. The trial court reasoned that while petitioner may not have intended to injure the children specifically, her negligent act caused injuries that were prejudicial to their development and left likely permanent scars. The RTC viewed R.A. No. 7610 as a special law under which intent was not necessary for liability and imposed indeterminate penalties of pris[i]on mayor, awarded actual and moral damages, and imposed fines under Section 31(f) of R.A. No. 7610.

Court of Appeals Ruling and Modification

The CA affirmed the RTC’s guilty findings but modified the penalties by setting the lower indeterminate term at prision correccional in its minimum period up to prision mayor in its maximum period (effectively reducing the lower threshold of the indeterminate sentence). The CA explained that although it concurred with the RTC’s credibility assessments, the RTC erred in asserting that intent need not be determined merely because the offense arises under a special law. The CA emphasized that whether a law is malum prohibitum depends on legislative intent, not label. Nevertheless, the CA concluded that petitioner had intent to harm CCC, and criminal liability attaches even when the actual victim differs from the intended victim; therefore the absence of specific intent to harm the children did not absolve petitioner.

Issues Raised in the Supreme Court Petition

Petitioner advanced two principal contentions: (1) the CA erred in affirming conviction under Section 10(a) of R.A. No. 7610 because petitioner allegedly lacked intent to debase or demean the intrinsic worth and dignity of the children (relying on Bongalon v. People), and (2) the CA erred in failing to apply Article 49 of the Revised Penal Code so that the penalty for the intended offense (physical injuries) rather than child abuse should be imposed.

Supreme Court’s Legal Analysis — Definition and Scope of Child Abuse

The Court analyzed statutory definitions in R.A. No. 7610 and its implementing rules, noting that “child abuse” as used in Section 3(b) encompasses physical abuse, including burns, and Section 10(a) punishes various acts of child abuse or being responsible for conditions prejudicial to a child’s development. The Court reaffirmed that Section 10(a) penalizes distinct acts (child abuse, child cruelty, child exploitation, and being responsible for other prejudicial conditions) and need not require proof of humiliation or debasement of the child’s dignity where the Information alleges physical abuse causing injuries prejudicial to development.

Application of Precedent on Intent and Error in Personae

The Court distinguished the present case from Bongalon (where the information explicitly alleged demeaning conduct and the lack of intent to humiliate affected classification of the offense). Here the Informations pleaded physical abuse by throwing boiling oil and resulting injuries prejudicial to the children’s development; petitioner did not deny throwing oil at CCC. The Court relied on Mabunot v. People to reiterate the principle that criminal liability may attach when the actor intended to commit an unlawful act upon one person but accidentally causes injury to another (error in personae), and that performing an inherently wrongful act establishes criminal intent for purposes of liability even if the precise victim differs. Consequently, petitioner’s admitted intention to pour hot oil at CCC, an unlawful act, sufficed to establish

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