Case Summary (G.R. No. 101897)
Petitioner and Respondent
Petitioner: Felina Rosaldes
Respondent: People of the Philippines
Key Dates and Applicable Law
• Offense: February 13, 1996
• RTC conviction: June 26, 2003 (Br. 27, Iloilo City)
• CA decision: May 11, 2005
• SCJ resolution: October 8, 2014
• Constitution: 1987 Philippine Constitution
• Statutes: R.A. No. 7610 (Child Abuse Law), Family Code Art. 233, Rules of Court
Factual Antecedents
Michael Ryan accidentally struck the teacher’s knee while she napped. She demanded an apology; when none was offered, she pinched him on the thigh, lifted him by the armpits, threw him to the floor, slammed him repeatedly by the ears and pushed him down a second time. He lost consciousness and later was found to have contusions, petechiae, lumbar tenderness and painful ambulation.
Procedural History
The Iloilo RTC convicted Rosaldes for violation of Section 10(a) of R.A. No. 7610, sentencing her to an indeterminate term of 4 years, 2 months, 1 day (prision correccional minimum) to 6 years, 1 day (prision mayor maximum). The Court of Appeals affirmed on May 11, 2005, adjusting the maximum to 10 years, 1 day of prision mayor. Rosaldes petitioned for certiorari.
Issues Presented
- Whether the acts constituted child abuse under R.A. No. 7610 or mere corporal discipline under the Revised Penal Code.
- Whether the information violated due process by failing to state essential elements.
Reviewability of Factual Findings
Under Rule 45, the Supreme Court’s review is confined to questions of law. No exception allowing re-evaluation of factual findings applies.
Child Abuse Analysis
The Court found the force and brutality of the petitioner’s conduct excessive and unrelated to legitimate disciplinary authority. Family Code Article 233 expressly forbids corporal punishment by teachers acting in loco parentis. R.A. No. 7610 Section 3(b)(2) defines child abuse to include any deed that “degrades or demeans the intrinsic worth and dignity” of a child; this standard was met.
Civil Liability and Damages
Both lower courts failed to assess civil liability ex delicto. The Supreme Court awarded:
• Moral damages: ₱20,000
• Exemplary damages: ₱20,000 (aggravating factor: public schoolteacher)
• Temperate damages: ₱20,000
Interest at 6% per annum from finali
Case Syllabus (G.R. No. 101897)
Antecedents
- On February 13, 1996, seven-year-old Michael Ryan Gonzales, a Grade 1 pupil at Pughanan Elementary School in Lambunao, Iloilo, accidentally bumped his teacher’s knee as he hurriedly entered the classroom.
- Petitioner Felina Rosaldes, a public schoolteacher, was asleep on a bamboo sofa and, upon being roused, demanded an apology which the child did not immediately offer.
- She pinched the boy’s thigh, lifted him by the armpits, and pushed him to the floor; he struck a desk, lost consciousness, and cried out as she then grabbed him by the ears and slammed him repeatedly.
- After resuming her class, Rosaldes left the injured child to go home, where he and classmates reported the incident to his mother and aunt, who in turn informed the Barangay Captain.
- The Barangay Captain advised a medical examination; Dr. Teresita Castigador of Dr. Ricardo Y. Ladrido Hospital documented:
- Petechiae and tenderness on both external ears (1×2 cm and 1×1 cm)
- Lumbar pain and tenderness at L3–L4
- Contusions on left inner thigh (two areas of 1×1 cm)
- Tenderness and painful ambulation at the femoral head area
- An Information for violation of Section 10(a), Article VI of R.A. 7610 (child abuse) was filed before the RTC, Branch 27, Iloilo City.
Facts
- Victim: Michael Ryan Gonzales, age 7, Grade 1 pupil.
- Perpetrator: Felina Rosaldes, public elementary schoolteacher.
- Date and place: February 13, 1996, Pughanan Elementary School, Lambunao, Iloilo.
- Sequence of events:
- Accidental knee bump → demand for apology → child proceeds to seat → pinching of thigh → lifting by armpits → forceful push to floor → loss of consciousness → repeated slamming by ears → class resumed.
- Witnesses: two classmates (Louella Loredo, Jonalyn Gonzales) who escorted the injured child home.
- Medical findings: documented bruises, petechiae, lumbar tenderness, contusions, and painful walking.
Procedural History
- RTC, Branch 27 (June 26, 2003): Convicted under RA 7610 § 10(a); sentenced to 4 years, 2 months, 1 day to 6 years, 1 day of imprisonment; civil liability not pronounced for lack of proof.
- CA (May 11, 2005): Dismissed appeal; modified penalty to indeterminate 4 years, 2 months, 1 day prision correccional (min.) to 10 years, 1 day pris