Beleta v. People
REITERATIONFacts
The Antecedents: Petitioner Billy Joe Beleta was charged with Lascivious Conduct under Section 5(b), Article III of Republic Act No. 7610, for allegedly exploiting and sexually abusing a 14-year-old minor. The Information alleged that on August 7, 2013, the petitioner, motivated by lewdness and using force and coercion, touched the victim's private parts against her will, threatening her with a knife and attempting to pull down her pants. The prosecution presented the victim's testimony, which detailed the incident, and a psychiatric evaluation of the victim by Dr. Benjamin Rodrigo Go, who diagnosed her with an acute disorder due to a traumatic event. The victim's birth certificate confirmed her age at the time of the incident. The petitioner denied the charges, claiming he was at a videoke bar with companions. Procedural History: The Regional Trial Court (RTC), Branch 10, Abuyog, Leyte, in Criminal Case No. 3336, convicted the petitioner of Lascivious Conduct and sentenced him to an indeterminate penalty of fourteen (14) years and eight (8) months to twenty (20) years imprisonment, along with civil indemnity, moral damages, and a fine. The RTC found the victim's testimony credible and rejected the petitioner's defenses of denial and alibi. On appeal, the Court of Appeals (CA) affirmed the RTC's judgment with modification, increasing the civil indemnity and moral damages to P50,000.00 each. The CA also found the victim's testimony credible and noted the victim's post-traumatic disorder as corroboration. The petitioner's motion for reconsideration was denied by the CA. The Petition: The petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's Decision and Resolution. The petition raised the issue of whether the petitioner's guilt for Lascivious Conduct was proven beyond reasonable doubt. The Supreme Court granted the petitioner's motion for extension to file the petition but ultimately denied the petition itself. The Court held that the issue of guilt beyond reasonable doubt is a factual matter not ordinarily reviewable under Rule 45, absent exceptional circumstances. The Court also noted the petitioner's failure to pay the required legal fees, though it relaxed the rule due to the petitioner's intent to pay and the gravity of the offense. The Court found no reversible error in the CA's affirmation of the lower courts' findings, upholding the conviction and the imposed penalties and damages, with the addition of exemplary damages.
Issue(s)
Whether the petitioner's guilt for the offense of Lascivious Conduct under Section 5(b), Article III of RA 7610 was proven beyond reasonable doubt. Whether the petition raises a question of law cognizable under Rule 45 of the Rules of Court.
Ruling
The Supreme Court denied the petition for review on certiorari. The Court affirmed the decision of the Court of Appeals, upholding the conviction of Billy Joe Beleta y Cayunda for Lascivious Conduct under Section 5(b), Article III of Republic Act No. 7610. The penalty imposed was affirmed, with modifications to the damages awarded.
Ratio Decidendi
On the issue of whether the petitioner's guilt was proven beyond reasonable doubt: The Court held that the prosecution sufficiently established the elements of Lascivious Conduct under Section 5(b), Article III of RA 7610. The victim, AAA, who was 14 years old at the time of the incident, testified that the petitioner caressed her breasts and vagina through coercion and intimidation, threatening her with a knife. The Court found AAA's testimony to be credible and convincing, noting that her narrative was more believable than the petitioner's denial and alibi, especially in light of the psychiatric evaluation of AAA by Dr. Go, which indicated an acute disorder due to a traumatic event. The Court reiterated that the phrase "other sexual abuse" in RA 7610 covers lascivious conduct committed through coercion or intimidation, and that a single instance of such abuse is sufficient for a violation. The Court also rejected the petitioner's contention that AAA's testimony was unbelievable due to the presence of other occupants or her reaction, stating that there is no standard behavior for victims of sexual abuse and that the close proximity of others does not render the commission of the offense impossible or incredible. The Court found the petitioner's defenses of denial and alibi to be negative and self-serving. These uncorroborated defenses could not prevail over the clear and credible narration of the incident by AAA and her positive identification of the petitioner as her abuser. The Court reiterated that denial and alibi are weak defenses, especially when contradicted by positive and credible evidence, and require strong and convincing corroboration to be given weight. The Court affirmed the indeterminate penalty of imprisonment for 14 years and 8 months, as minimum, to 20 years, as maximum, as it falls within the range provided by law for the offense of Lascivious Conduct under RA 7610. The Court also affirmed the awards of civil indemnity and moral damages at ₱50,000.00 each, and added exemplary damages of ₱50,000.00, consistent with jurisprudence. The fine of ₱15,000.00 was also affirmed pursuant to Section 31(f), Article XII of RA 7610, which mandates that such fines be administered by the Department of Social Welfare and Development for the rehabilitation of the child victim. On the issue of whether the petition raises a question of law cognizable under Rule 45: The Court emphasized that the issue of guilt beyond reasonable doubt is a factual question. Under Rule 45 of the Rules of Court, the Supreme Court's jurisdiction is limited to reviewing errors of law, not facts, unless there are exceptional circumstances. Since the petitioner failed to sufficiently show any reversible error of law committed by the lower courts, and the factual findings of the RTC and CA were consistent and supported by evidence, the petition was dismissed on this ground alone. The Court noted that it is not a trier of facts and will not substitute its own judgment for that of the lower courts on factual matters that have been thoroughly passed upon and resolved. While noting the petitioner's failure to pay the required legal fees, the Court chose to relax this mandatory and jurisdictional requirement due to the petitioner's intention to pay, as evidenced by the postal money order, and the gravity of the offense charged. However, the petitioner was directed to pay the Sheriff's Trust Fund within 10 days from receipt of the Resolution.
Main Doctrine
A petition for review on certiorari under Rule 45 of the Rules of Court is limited to reviewing errors of law, not facts, unless exceptional circumstances warrant otherwise. The Court will not disturb the factual findings of the lower courts, particularly the credibility of witnesses and their appreciation of evidence, if no reversible error is shown.