G.R. No. 261049 , June 26, 2023
XXX261049, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner XXX261049 was charged with four counts of violating Section 4(a) of Republic Act No. 9995 (Anti-Photo and Video Voyeurism Act of 2009). The Informations alleged that on or about October 11, 2016, he willfully took video coverage of his nieces AAA261049, BBB261049, CCC261049, and DDD261049 while they were taking a bath, capturing their private areas without their consent and while they had a reasonable expectation of privacy. The prosecution established that the victims, who are sisters and a cousin, lived together, and XXX261049, their uncle, frequented their house to supervise a renovation. AAA261049 testified that on October 11, 2016, she saw XXX261049 enter the bathroom and, upon taking her turn, discovered a Blackberry phone inside a Safeguard soap box on a shelf, with its camera positioned to record the bath area. The phone was recording, and she recognized it as belonging to XXX261049. She checked the phone and found videos of herself and the other victims naked while bathing. She captured snippets and stills of the videos using her own phone, deleted the videos from XXX261049’s phone, and reported the incident. The other victims corroborated her testimony and identified the printed stills. Richard Castillo, a construction worker, testified that he and his co-workers had no access to the bathroom. XXX261049 denied the accusations, claiming he lost a similar phone months prior and that the charges were fabricated because his nieces resented his discipline. The Regional Trial Court (RTC) convicted XXX261049 in Criminal Case Nos. 18882, 18883, and 18884 but acquitted him in Criminal Case No. 18885 due to insufficient evidence (no photo or video of DDD261049 was presented). The Court of Appeals (CA) affirmed the RTC’s decision. XXX261049 filed a Petition for Review on Certiorari, arguing that the evidence against him was entirely circumstantial and insufficient for conviction.

ISSUE

Was XXX261049’s guilt for the violation of Section 4(a) of RA No. 9995 proven beyond reasonable doubt?

RULING

Yes. The Supreme Court affirmed the conviction, holding that guilt was proven beyond reasonable doubt through circumstantial evidence. The Court emphasized that circumstantial evidence is sufficient for conviction if the circumstances constitute an unbroken chain leading to a fair and reasonable conclusion of guilt. The circumstances proven were: (1) XXX261049 had free access to the house and was seen entering the bathroom before the discovery; (2) the phone used was identified as belonging to him, as he was the only one in the household with that type of phone; (3) the phone was strategically placed inside a soap box to record the bath area; (4) the videos contained footage of the victims in a private act; (5) the victims had a reasonable expectation of privacy in the bathroom; and (6) XXX261049’s denial and claim of a lost phone were unconvincing and could not overcome the positive testimonies and evidence. The Court found these circumstances formed a cohesive and conclusive narrative of guilt. The penalties and awards of moral damages, exemplary damages, and attorney’s fees imposed by the RTC were upheld. The Court also imposed legal interest on the damages from the finality of judgment until fully paid.