Delos Santos v. People
REITERATIONFacts
The Antecedents: On August 31, 2007, AAA, a 17-year-old minor, and her companion Clemente Daluro, Jr. were on their way home when they were confronted by Joseph Delos Santos y Padrinao (Delos Santos) and his group. Bob Delos Santos, Joseph's brother, uttered "nag-iinit na ako" and attempted to hit Daluro with a rock. AAA apologized to prevent a commotion, but Bob insisted he was not holding a rock. Joseph Delos Santos attempted to punch Daluro, but missed and hit AAA on the right cheek. Bob then punched AAA on the chest, causing her to hit a wall. Bob stated, "tama lang yan sa inyo pagtripan dahil dinemanda n'yo kami." Joseph Delos Santos hurled invectives at AAA and Daluro. Delos Santos' group followed AAA and Daluro home. Upon seeing the terrace light turned on by AAA's mother, they fled. AAA reported the incident to the barangay and was treated at Valenzuela General Hospital for a "contusion at the right supraorbital area, secondary to mauling." Procedural History: The Information charged Delos Santos with slight physical injuries in relation to R.A. No. 7610. Delos Santos pleaded not guilty. The RTC found Delos Santos guilty beyond reasonable doubt of violating Section 10(a), Article VI of R.A. No. 7610 and imposed a penalty of imprisonment and moral damages. Delos Santos appealed to the Court of Appeals (CA), which affirmed the RTC's decision. Delos Santos filed a motion for reconsideration, which was denied. He then filed a petition for review on certiorari before the Supreme Court. The Petition: Delos Santos assailed the CA's decision and resolution, arguing that the CA erred in affirming the RTC's conviction despite the prosecution's alleged failure to establish all the elements of child abuse under Section 10 of R.A. No. 7610. He claimed the issue involved a misapprehension of facts and overlooked relevant facts.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court's Decision finding the petitioner guilty beyond reasonable doubt of violating Section 10(a), Article VI of Republic Act No. 7610; specifically, whether the issue presented was factual in nature and thus not a proper subject for a petition for review on certiorari. Whether the prosecution established all the elements of the crime of child abuse under Section 10 of R.A. No. 7610, including psychological and physical abuse, neglect, cruelty, sexual abuse, and emotional maltreatment, as well as acts that debase, degrade, or demean the intrinsic worth and dignity of a child.
Ruling
The petition is denied. The Court affirmed the Decision and Resolution of the Court of Appeals with modification regarding the indeterminate penalty. The moral damages awarded shall earn an interest of 6% per annum from the date of finality of the Decision until fully paid. The minimum indeterminate penalty imposed is prision correccional in its maximum period of four (4) years, two (2) months, and one (1) day, and the maximum indeterminate penalty is prision mayor in its medium period of six (6) years, eight (8) months and one (1) day.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the conviction and whether the issue presented was factual in nature: The Court held that the issue presented was factual in nature, and thus not a proper subject for a petition for review on certiorari under Rule 45 of the Rules of Court, as it required a reevaluation of the evidence. The Court reiterated that it is not a trier of facts, and the evaluation of evidence is the function of the trial court. The Court found no reversible error in the CA's affirmation of the RTC's conviction. On the issue of whether the prosecution established all elements of child abuse under R.A. No. 7610: The elements of child abuse under Section 10(a) of R.A. No. 7610, which includes psychological and physical abuse, neglect, cruelty, sexual abuse, and emotional maltreatment, as well as acts that debase, degrade, or demean the intrinsic worth and dignity of a child, were deemed established. The Court noted that intent, though internal, can be inferred from external acts. The circumstances, including the unprovoked approach by Delos Santos' group, the threatening words, the physical assault on AAA and Daluro, the hurling of invectives, and the pursuit of the victims, demonstrated Delos Santos' intent to debase and degrade AAA. The Court distinguished this case from Bongalon v. People, where the acts were considered spur-of-the-moment and done in anger, unlike the deliberate acts of revenge in the present case. Delos Santos' alibi was considered weak and unsubstantiated against the clear evidence presented by the prosecution. The Court found that the acts of Delos Santos and his group constituted physical and psychological child abuse, and emotional maltreatment, which debase, degrade, and demean the intrinsic worth and dignity of a child as a human being.
Main Doctrine
The Court affirmed the conviction of the petitioner for violating Section 10(a) of R.A. No. 7610, finding that the acts of approaching the victim and her companion, uttering threatening words, attempting to punch the victim's companion which hit the victim, punching the victim, hurling invectives, and following them home, demonstrated intent to debase, degrade, and demean the intrinsic worth and dignity of the child, constituting psychological and physical abuse and emotional maltreatment. The Court also reiterated that a petition for review on certiorari under Rule 45 of the Rules of Court primarily raises questions of law, and issues involving the evaluation of evidence are questions of fact, which are generally not proper subjects for such petitions, unless exceptions apply.