G.R. No. 269372 , November 26, 2024
RYAN M. SUMILE, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Ryan M. Sumile was charged with violation of Article VI, Section 10(a) of Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act). The Information alleged that on October 7, 2014, Ryan willfully committed physical and psychological violence upon an 8-year-old boy, AAA, inside the latter’s school. The acts included uttering angry words, grabbing and twisting AAA’s arms, ordering his own son to box AAA, pulling AAA’s hair, boxing the sides and top of AAA’s head, and threatening to kill him. These acts allegedly caused intense physical pain and fright, debasing the minor’s intrinsic worth and dignity, and were prejudicial to his normal growth and development. Ryan pleaded not guilty. The prosecution presented AAA, his teacher CCC, a psychologist, and a doctor. AAA testified that Ryan assaulted him after a fistfight with Ryan’s son, BBB. The psychologist found AAA exhibited tension and fear from the traumatic experience, and the doctor stated his headaches could have been caused by being hit. The defense presented Ryan as its sole witness, who claimed he merely separated the fighting children. The Regional Trial Court found Ryan guilty and sentenced him to an indeterminate penalty. The Court of Appeals affirmed the conviction. Ryan filed a Petition for Review on Certiorari, arguing his acts lacked the specific intent to debase AAA’s intrinsic worth and were merely prompted by seeing his son being boxed.

ISSUE

Whether the Court of Appeals erred in affirming Ryan M. Sumile’s conviction for violation of Section 10(a), Article VI of Republic Act No. 7610 .

RULING

The petition is denied. The Supreme Court affirmed the conviction. Preliminarily, the petition suffered from procedural infirmities including failure to attach the questioned judgment, affidavit of service, and registry receipts, and failure to pay fees on time, warranting dismissal. Furthermore, the issue raised—whether Ryan’s acts were done with intent to debase AAA’s intrinsic worth—is a question of fact, not reviewable in a Rule 45 petition. In any event, the lower courts did not err. The elements of the crime under Section 10(a) of R.A. 7610 are: (1) the accused commits an act of child abuse, cruelty, or exploitation, or is responsible for conditions prejudicial to the child’s development; (2) the act is not covered by the Revised Penal Code; and (3) the child is below 18 years of age. Ryan’s acts of punching, slapping, hair-pulling, and throwing the 8-year-old victim, coupled with threats, constituted psychological and physical abuse. These acts, done in the presence of the victim’s teacher and schoolmates, were intrinsically cruel, excessive, and intended to humiliate and traumatize, thereby debasing the child’s dignity and worth, and were prejudicial to his normal development. The defense of provocation was untenable. The penalty imposed by the trial court, as affirmed by the Court of Appeals, was in accordance with law.