G.R. No. 245516 , June 14, 2021
Michael John Dela Cruz y Sodela, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner Michael John Dela Cruz y Sodela, a teacher, was charged with five counts of violating Republic Act No. 7610 (Special Protection of Children Against Child Abuse, Exploitation, and Discrimination Act) before the Regional Trial Court (RTC). The Informations alleged that on various dates in 2016, with lewd design and using force, coercion, and his influence, he committed sexual acts against three minor students (AAA, BBB, and CCC), all 13 years old at the time. The specific acts included kissing and fondling AAA’s breasts, asking BBB to kiss him, touching BBB’s thigh, and commanding CCC to kiss her boyfriend and perform lascivious acts. Upon arraignment, petitioner pleaded not guilty. The prosecution presented the testimonies of the minor victims and a guidance counselor, establishing that petitioner, leveraging his position as a teacher, made sexual advances towards the students, who complied out of fear of receiving failing grades. The defense presented denial, claiming the victims were influenced by a grudge and that his actions were misinterpreted. The RTC convicted petitioner for two counts of sexual abuse under Section 5(b) of R.A. No. 7610 and three counts of child abuse under Section 10(a) of the same law. The Court of Appeals affirmed the RTC’s decision with modifications to the penalties and damages.

ISSUE

The core issue is whether the Court of Appeals correctly affirmed petitioner’s conviction for violations of Sections 5(b) and 10(a) of R.A. No. 7610 .

RULING

The Supreme Court denied the petition and affirmed the findings of the lower courts with modifications. The Court held that all elements of the crimes were proven beyond reasonable doubt. For the violations of Section 5(b) (sexual abuse), the Court found that petitioner, a teacher with moral ascendancy over the victims, committed lascivious acts (kissing and fondling) against AAA, a child exploited in prostitution or subjected to other sexual abuse. The Court emphasized that the law protects children from any form of sexual abuse, and the perpetrator’s moral ascendancy substitutes for the use of force or intimidation. For the violations of Section 10(a) (other acts of child abuse), the Court found that petitioner’s acts of asking BBB to kiss him, touching her thigh, and commanding CCC to perform lascivious acts constituted psychological abuse and cruelty, debasing the intrinsic worth of the child, and were prejudicial to the child’s development. The Court rejected petitioner’s defense of denial as weak and unsupported by evidence, and upheld the credibility of the minor victims’ testimonies. The penalties and damages were modified in accordance with prevailing jurisprudence: for each count under Section 5(b), an indeterminate penalty of 14 years and 8 months of reclusion temporal minimum to 20 years of reclusion temporal maximum, with civil indemnity, moral damages, and exemplary damages of P75,000 each; for each count under Section 10(a), a penalty of 4 years, 9 months, and 11 days of prision correccional minimum to 8 years of prision mayor minimum, with civil indemnity, moral damages, and exemplary damages of P50,000 each. All damages were subject to 6% interest per annum from finality of judgment until full payment.