Case Summary (G.R. No. 228980)
Applicable Law
This case primarily hinges on Republic Act No. 7610 (RA 7610), specifically Article III, Section 5(b), which penalizes lascivious conduct towards minors. The law aims to provide stronger deterrence against child abuse, exploitation, and discrimination.
Facts of the Case
The factual background reveals that on November 25, 2010, while AAA and her friends were using a non-working escalator, Villanueva allegedly lifted AAA's skirt and touched her buttocks. This act was witnessed by AAA's friend, BBB, who yelled for help, leading to Villanueva's apprehension by traffic enforcer Tolentino and later by police officers. Villanueva denied the allegations, claiming he was merely trying to pass by AAA in a crowded area while holding his cellphones.
RTC Ruling
In its decision dated August 28, 2013, the RTC found Villanueva guilty beyond reasonable doubt and sentenced him to an indeterminate prison term ranging from eight years and one day to 17 years, four months, and one day, along with the payment of moral and exemplary damages to AAA. The RTC emphasized the credibility of AAA's testimony, which was corroborated by eyewitness accounts, solidifying the case against Villanueva.
CA Ruling
The CA upheld the RTC's verdict in its decision on October 28, 2016, modifying the penalty to a range of 14 years and eight months to 20 years of reclusion temporal, and increasing the damages awarded to AAA. It reaffirmed that all elements of sexual abuse under RA 7610 were satisfied based on the nature of Villanueva's actions and AAA’s age at the time of the incident.
Issue for Resolution
The central issue before the Supreme Court was whether the CA rightly affirmed Villanueva's conviction for violating Article III, Section 5(b) of RA 7610. Villanueva contended that there was insufficient evidence of lewd design and that his actions could not be construed as lascivious conduct given the circumstances he described.
Court's Ruling
The Supreme Court found no merit in Villanueva's arguments, affirming the findings of the lower courts. The Court determined that the prosecution successfully proved each element of lascivious conduct, noting that AAA's minority was established and her credible testimony clearly described Villanueva's actions. The Court ruled that Villanueva's defense of denial was inadequate against the strong evidence provided by the prosecution.
Modification of Ruling
The Court clarified that while Villanueva was described as guilty of violating Section 5(b) of RA
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Procedural Posture
- Petition for Review on Certiorari filed under Rule 45 of the Rules of Court.
- The Petition assails the Decision dated October 28, 2016, and the Resolution dated January 4, 2017, of the Court of Appeals (CA).
- These CA rulings affirmed with modification the RTC Decision dated August 28, 2013, in Crim. Case No. 10-0985.
- RTC found petitioner Marvin Villanueva guilty beyond reasonable doubt for violation of Article III, Section 5(b) of Republic Act (RA) No. 7610.
Facts of the Case
- Villanueva was charged with violation of Sec. 5(b), RA 7610, for an act on November 25, 2010, in a Philippine city within RTC jurisdiction.
- The charge states Villanueva willfully, unlawfully, and feloniously pulled up the skirt and touched the buttocks of AAA, constituting sexual abuse.
- AAA was 15 years old at the time; evidence included her Certificate of Live Birth.
- Incident occurred at around 4:00 p.m. on a nonworking escalator in an overpass.
- AAA was accompanied by her friend BBB and BBB's 11-year-old sister CCC when Villanueva stood behind AAA.
- BBB warned AAA; AAA felt her skirt lifted and buttocks touched; she saw Villanueva holding a mirror under her skirt.
- Villanueva fled towards a highway amid bystanders' calls for help.
- Enforcer Tolentino apprehended Villanueva, who was later handed to police officers and taken for investigation.
Defense's Version
- Villanueva denied allegations and claimed he was sent by his mother to buy pancit.
- He rode a tricycle, got off at a location near the escalator, and saw female students greeting each other.
- While holding two cellular phones, Villanueva tried to overtake AAA on the left side of the escalator.
- Hearing shouts of "Snatcher," he put phones in his pockets and fled to avoid being mobbed by bystanders.
- He asked for Enforcer Tolentino's help as he was being pursued and subsequently handcuffed.
- Police officers took him to the station for further investigation.
RTC Ruling
- The RTC found Villanueva guilty beyond reasonable doubt of violating RA 7610, Section 5(b).
- Sentenced to indeterminate imprisonment: minimum of eight years and one day to maximum of 17 years, four months, and one day.
- Ordered to pay PHP 10,000.00 as moral damages and PHP 5,000.00 exemplary damages to AAA.
- RTC gave full credence to AAA's testimony, noting the sufficiency of the offended party's credible testimony in sexual abuse cases.
- BBB's corroboration strengthened AAA's account.
- All elements of sexual abuse were present; lewd design inferred from overt act of lifting skirt and touching buttocks.
Court of Appeals Decision
- The CA affirmed the conviction with modifications on penalty and damages.
- Revised sentence: imprisonment from 14 years and eight months to 20 years of reclusion temporal.
- Imposed a fine of PHP 15,000.00 and increased damages: PHP 20,000.00 civil