GR 254005; (June, 2021) (Digest)
G.R. No. 254005 , June 23, 2021
Asela Briñas y Del Fierro, Petitioner, vs. People of the Philippines, Respondent.
FACTS
Petitioner Asela Briñas was the directress and owner of Challenger Montessori School. On January 25, 2010, she called two 16-year-old students, Micolle Mari Maevis Rosauro and Keziah Liezle Dolojan, and their classmates to the faculty room. The students had sent a text message to a classmate using the name of Briñas’s daughter. In front of teachers and other students, Briñas shouted at them, uttered defamatory words including “pinakamalalandi, pinakamalilibog, pinakamahadera at hindot” and “Mga putang ina kayo,” and raised her middle finger. The private complainants were suspended, later expelled just before graduation, and their school records were withheld, delaying their college enrollment. They suffered emotional distress, with Keziah exhibiting symptoms of Post-Traumatic Stress Disorder. Briñas was charged with Grave Oral Defamation in relation to Section 10(a) of Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act). The Regional Trial Court convicted her, a decision affirmed with modification by the Court of Appeals. Briñas filed a Petition for Review on Certiorari.
ISSUE
Whether the Regional Trial Court and the Court of Appeals erred in convicting Briñas of the crime of grave oral defamation in relation to Section 10(a) of R.A. 7610.
RULING
The Supreme Court granted the petition. It ruled that there is no crime of “grave oral defamation in relation to Section 10(a) of R.A. 7610.” Section 10(a) of R.A. 7610 explicitly punishes acts of child abuse “not covered by the Revised Penal Code.” Since grave oral defamation is defined and punished under the Revised Penal Code, it cannot be prosecuted in relation to Section 10(a) of R.A. 7610, as the acts covered by each law are mutually exclusive. The Court further found that Briñas’s acts did not constitute child abuse under Section 3(b)(2) of R.A. 7610, which requires a specific criminal intent to debase, degrade, or demean the intrinsic worth and dignity of a child. The evidence showed Briñas acted out of a desire to discipline the students within the scope of her special parental authority, without the specific malicious intent required by the law. The Court acquitted Briñas of the crime charged and ordered her immediate release.