G.R. No. 169143 ; February 2, 2007
People of the Philippines, Appellee vs. Simplicio Delantar, Appellant.

FACTS

An Information charged Simplicio Delantar with violating Section 5, Article III of Republic Act No. 7610 (the Special Protection of Children Against Abuse, Exploitation and Discrimination Act). The prosecution alleged that from 1994 to August 1996, Delantar, through coercion and influence, promoted and facilitated his daughter, AAA, a child below 12 years old, to engage in sexual intercourse and lascivious conduct for money and profit. The evidence presented detailed two specific instances: Delantar delivered AAA to an Arab national named Hammond and later to Congressman Romeo Jalosjos, during which AAA was subjected to various sexual acts.
The Regional Trial Court convicted Delantar of two counts under R.A. No. 7610 , sentencing him to two penalties of reclusion perpetua. On appeal, the Court of Appeals modified the decision, holding that only one offense was charged in the single Information, thus convicting him of only one count. It affirmed the conviction but modified the damages awarded. Delantar appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and contesting the imposition of the maximum penalty.

ISSUE

The core issues were: (1) whether the prosecution proved Delantar’s guilt beyond reasonable doubt for child prostitution under R.A. No. 7610 , and (2) whether the penalty of reclusion perpetua was correctly imposed.

RULING

The Supreme Court affirmed the conviction and the penalty. On the first issue, the Court found the testimony of the minor victim, AAA, to be credible, consistent, and sufficient to establish guilt. AAA’s detailed account of how her father delivered her to clients for sexual exploitation was corroborated by other evidence, including her birth certificate proving she was below 12 years old at the time. The Court emphasized that in cases of child abuse, the victim’s testimony, given its credible and straightforward nature, is enough to sustain a conviction.
On the second issue regarding the penalty, the Court explained the legal logic under Section 5 of R.A. No. 7610 . The law prescribes a penalty of reclusion temporal in its medium period to reclusion perpetua for those who promote or facilitate child prostitution. The Court ruled that when the victim is below twelve (12) years of age, the penalty shall be imposed in its maximum period, which is reclusion perpetua. Since AAA was proven to be eleven years old during the commission of the offense, the imposition of reclusion perpetua was mandatory and correct. The Court found no error in the penalty imposed, as the qualifying circumstance of the victim’s age was duly established and warranted the maximum penalty under the law.