Title
Quimvel y Braga vs. People
Case
G.R. No. 214497
Decision Date
Apr 18, 2017
A caretaker convicted under RA 7610 for acts of lasciviousness against a 7-year-old; courts upheld findings, emphasizing child protection.

Case Summary (G.R. No. 214497)

Petitioner

Eduardo Quimvel y Braga, also known as Edward/Edward Quimuel y Braga

Respondent

People of the Philippines

Key Dates

July 18, 2007 – Alleged commission of lascivious conduct
January 23, 2013 – RTC judgment convicting Quimvel
May 29, 2014 – CA decision affirming conviction with modification of damages
April 18, 2017 – Supreme Court decision

Applicable Law

1987 Constitution, Article III, Section 14(2) (right to be informed of nature and cause of accusation)
Rule 45, Rules of Court (petition for review on certiorari)
Republic Act No. 7610, Section 5(b), Article III (child prostitution and other sexual abuse)
Revised Penal Code, Article 336 (Acts of Lasciviousness)

Facts

AAA, aged seven, lived with her father YYY and siblings in Ligao City. Quimvel served as caretaker of AAA’s grandfather’s ducks and resided nearby. On the evening of July 18, 2007, YYY left home to buy kerosene. Quimvel arrived bearing a vegetable viand from AAA’s grandfather. At AAA’s request, he stayed overnight. AAA fell asleep and later awoke to Quimvel’s right leg pressing on her and his right hand inside her undergarment, caressing her vagina. She removed his hand; he departed upon YYY’s return.

Trial Court Ruling

The RTC found AAA’s testimony straightforward and categorical, establishing guilt beyond reasonable doubt for Acts of Lasciviousness under R.A. 7610 Section 5(b). Quimvel was sentenced to reclusion temporal in its medium period, 14 years, 8 months, 1 day to 15 years, 6 months, 19 days, and ordered to pay P30,000 moral damages and P30,000 fine, with credit for preventive detention.

Appellate Court Ruling

The CA affirmed the conviction but modified damages: P15,000 each for moral and exemplary damages, P20,000 civil indemnity, all earning 6% interest from finality.

Issues on Review

  1. Whether the prosecution proved guilt beyond reasonable doubt.
  2. Whether, if guilty, Quimvel could be convicted only under RPC Article 336 rather than in relation to R.A. 7610 Section 5(b).

Supreme Court Ruling

The petition is denied. Quimvel is guilty beyond reasonable doubt of Acts of Lasciviousness under R.A. 7610 Section 5(b). The CA Decision is affirmed with modification of the prison term in accordance with the Indeterminate Sentence Law.

Reasoning

• Information Alleges Essential Elements—The Information specified the accused’s identity, offense designation (Acts of Lasciviousness in relation to Section 5(b) of R.A. 7610), time, place, and the lascivious acts by force and intimidation on a seven-year-old. This satisfied Rule 110, Sections 6 and 9, and Article III, Section 14(2) of the Constitution.
• Section 5(b) Elements Alleged—To convict under R.A. 7610 Section 5(b), prosecution must show: (1) commission of sexual intercourse or lascivious conduct; (2) act performed on a child exploited in prostitution or subjected to other sexual abuse; (3) child under 18. The Information alleged force and intimidation and that AAA, a minor of seven, was the victim; “force and intimidation” falls under “coercion or influence.”
• “Coercion or Influence” and “Force and Intimidation”—Black’s Law Dictionary and jurisprudence treat the terms as synonymous: both denote compulsion subduing the offended party’s free will. Section 2(g) of the Rules on Child Abuse likewise defines “influence” and “coercion” broadly to include persuasion or improper use of power.
• One-Time Abuse Suffices—R.A. 7610 covers habitual or non-habitual sexual abuses (Section 3(b)). Jurisprudence (Olivarez, Larin, Garingarao) confirms a single act of lascivious conduct under coercion or influence subjects the child to “other sexual abuse.”
• Credibility of Witness Testimony—AAA’s unshaken, detailed testimony that Quimvel awoke her, inserted his hand, and caressed her vagina, credibly established each e

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