G.R. No. 227581, January 15, 2020
JOSEPH DELOS SANTOS Y PADRINAO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

The petitioner, Joseph Delos Santos y Padrinao, was charged with slight physical injuries in relation to Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act). The Information alleged that on August 31, 2007, in Valenzuela City, Delos Santos, conspiring with others, willfully mauled AAA, a 17-year-old minor, hitting her on the face and chest, inflicting injuries requiring medical attendance for less than nine days. The prosecution presented AAA and her companion, Clemente Daluro, Jr., as witnesses. AAA testified that Delos Santos and his group, including his brother Bob, confronted them without provocation. Bob stated “nag-iinit na ako” and threatened Daluro with a rock. When Delos Santos attempted to punch Daluro, AAA was hit on the cheek instead. Bob then punched AAA on the chest, causing her to hit a wall. Bob remarked, “tama lang yan sa inyo pagtripan dahil dinemanda n’yo kami,” and Delos Santos hurled invectives at AAA. The group followed AAA and Daluro until AAA’s mother intervened. AAA suffered a contusion and reported the incident. At the barangay, four men apologized, but Delos Santos and Bob did not. The defense presented Delos Santos, who denied the charges and claimed he was at his sister’s store, and a purok leader who testified no incident was logged that night. The Regional Trial Court convicted Delos Santos, imposing an indeterminate penalty and moral damages. The Court of Appeals affirmed the conviction. Delos Santos filed a Petition for Review on Certiorari before the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s Decision convicting the petitioner of violating Section 10(a), Article VI of R.A. No. 7610.

RULING

The Supreme Court denied the petition. It held that the issue raised was factual in nature, involving a reevaluation of evidence to determine if all elements of the crime were established, which is not permissible in a Rule 45 petition limited to questions of law. The Court found no error in the appellate court’s decision. It ruled that the prosecution proved beyond reasonable doubt that Delos Santos committed child abuse under R.A. No. 7610. The acts—confronting without provocation, attempting to punch, hitting the minor, uttering threatening and demeaning words motivated by revenge (“tama lang yan sa inyo pagtripan dahil dinemanda n’yo kami”), hurling invectives, and following the victim—constituted physical and psychological abuse that debased, degraded, and demeaned the intrinsic worth and dignity of the child. The Court modified the penalty, imposing a minimum indeterminate penalty of prision correccional in its maximum period (4 years, 2 months, 1 day) and a maximum indeterminate penalty of prision mayor in its medium period (6 years, 8 months, 1 day). It also affirmed the award of moral damages with 6% interest per annum from the finality of the decision until fully paid.