Case Summary (G.R. No. 268457)
Antecedents
XXX faced three separate Informations for child abuse, specifically violating Section 10(a) of Republic Act No. 7610. The charges stemmed from incidents involving his children, BBB and AAA, where he allegedly inflicted physical harm on them.
Incident Overview
In Criminal Case No. 4556-M-2018, on February 21, 2018, XXX reportedly attacked BBB in a manner that caused physical injuries. In case No. 4557-M-2018, on the same date, he assaulted AAA by pulling her hair and striking her, leading to physical injuries. In the third case, No. 4558-M-2018, on September 22, 2017, he struck AAA with a wooden rod embedded with a nail.
Trial Proceedings
Upon arraignment, XXX pleaded not guilty. During the trial, the prosecution presented testimonies from both children, confirming they were victims of their father's abuse. The children described distressing encounters wherein their father's violent responses to minor issues, such as a perceived lack of obedience regarding meal times and money, led to physical injuries. The defense presented XXX, who denied the allegations, claiming he only sought to discipline his children.
Court Findings
The Regional Trial Court (RTC) found the children's testimonies credible, emphasizing their sincerity and coherence regarding the abuses suffered. The RTC deemed XXX's defense inconsistent and deemed his actions as not justifiable disciplinary measures. It highlighted the severity and nature of the injuries, concluding that the younger children's dignity had been degraded through his actions.
RTC Decision
The RTC convicted XXX on all counts and sentenced him to an indeterminate prison term. Each conviction was supported by credible testimony and medical evidence confirming injuries resulting from the alleged assaults. The court reinforced that any form of abuse, particularly that which serves to debase a child's dignity, is intolerable.
Appeal to the Court of Appeals
Dissatisfied, XXX appealed to the Court of Appeals (CA), which modified the RTC's judgement, reducing the damages awarded to the children while affirming the convictions. The CA underscored the abusive conduct and maintained that XXX's intent to demean the dignity of his children was evident from the nature of his actions.
Motion for Reconsideration
XXX filed a motion for reconsideration which was denied, leading him to seek further redress through a Petition. He continued to assert that the prosecution had not proven his intent to debase or demean his children and portrayed his actions as mere parental frustration and miscommunication.
Legal Arguments
The prosecution, represented by the Office of the Solicitor General, countered XXX's claims by asserting that his violent actions were demonstrably abusive and degrading, meeting the elements of crimes set forth in Republic Act No. 7610.
Issue for Resolution
The central issue was whether the prosecution sufficiently demonstrated beyond a reasonable doubt that XXX was guilty of child abuse as defined under Republic Act No. 7610.
Supreme Court Rulings
The Supreme Court dismissed the petition, ruling that XXX's arguments primarily reiterated those presented to the CA, focusing on factual matters rather than legal errors. The Cou
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Background and Procedural History
- Petitioner XXX was charged with three counts of child abuse under Section 10(a) of Republic Act No. 7610, also known as the Special Protection of Children Against Abuse, Exploitation and Discrimination Act.
- The charges stem from two separate incidents where petitioner allegedly physically assaulted his minor children, AAA (12 years old) and BBB (10 years old).
- The Regional Trial Court (RTC) found XXX guilty beyond reasonable doubt and imposed penalties including imprisonment and moral damages.
- The Court of Appeals (CA) affirmed the RTC's decision with modifications, particularly reducing the quantum of damages and adding exemplary and temperate damages as well as fines.
- Petitioner filed a Petition for Review on Certiorari to the Supreme Court, contesting the findings and penalties imposed.
Facts of the Case
- On September 22, 2017, petitioner hit AAA several times with a wooden rod embedded with a nail, causing physical injuries while cursing her for not eating lunch before delivering food.
- Around February 21, 2018, petitioner allegedly pulled AAA's hair, kicked her, and struck her head and also hit BBB multiple times with a dustpan over a dispute regarding money in their coin banks.
- Both children left the home and sought refuge with their mother, CCC, and were medically examined confirming physical injuries.
- Petitioner admitted to striking the children but asserted it was disciplinary action and denied the claim of abuse.
Trial Court Findings
- The RTC gave full credence to the testimonies of the children, finding them straightforward and sincere.
- The court found the petitioner’s testimony inconsistent and unreliable, noting admissions that pointed to repeated incidents.
- It was established that petitioner’s acts of cursing and physically hitting his children with objects debased, degraded, and demeaned their intrinsic worth and dignity.
- The acts were found excessive an