G.R. No. 271940 , January 22, 2025
XXX271940, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner XXX271940 was charged with child abuse under Section 10(a) of Republic Act No. 7610 . The Information alleged that on July 13, 2017, he, being the father of the 8-year-old minor AAA271940, with intent to abuse and inflict conditions prejudicial to a child’s development, willfully rushed inside their residence, closed its door while carrying a bolo, thereby giving the minor the impression that he would rape or sexually assault her. The prosecution presented the testimonies of the victim (AAA271940), her sister (BBB271940), and a psychiatrist (Dr. Hazel Eiza C. Soriano-Biclar). AAA testified that while she was preparing pig feeds, her father, holding a bolo, closed the kitchen door and approached her, causing her to run away as she thought he would do something bad, specifically fearing it would be the fifth time he would rape her. The psychiatric evaluation revealed the victim suffered trauma, feelings of rejection, helplessness, immaturity, dependency, timidity, and fearfulness. The defense waived its right to present evidence. The Regional Trial Court (RTC) convicted XXX271940, imposing an indeterminate penalty and ordering him to pay moral damages. The Court of Appeals (CA) affirmed the RTC’s decision. Petitioner filed this Petition for Review on Certiorari, arguing the prosecution failed to prove all elements of child abuse, specifically the intent to degrade or demean the child’s inherent value and dignity.

ISSUE

Whether petitioner XXX271940 is guilty of child abuse under Section 10(a) of Republic Act No. 7610 .

RULING

The Petition is denied. The Supreme Court affirmed the conviction. As a rule, a petition for review under Rule 45 is confined to questions of law, and the issue of sufficiency of evidence is a question of fact. The Court found no reason to depart from the concurrent factual findings of the RTC and CA, which were adequately supported by evidence. Even assuming a scrutiny of the arguments, the conviction stands. Section 10(a) of R.A. 7610 punishes acts of child abuse, cruelty, exploitation, or conditions prejudicial to the child’s development. “Child abuse” is defined under Section 3(b) of the same law. The Court, citing San Juan v. People, distinguished the intents required: Section 3(b)(1) requires only a general criminal intent to commit the physical or psychological abuse, while Section 3(b)(2) requires a specific intent to debase, degrade, or demean the child’s intrinsic worth. The act charged and proven—rushing in with a bolo and closing the door, causing the child to fear imminent rape based on her past traumatic experiences—constitutes psychological abuse under Section 3(b)(1). The prosecution successfully established the elements of the offense, and the psychological evaluation corroborated the trauma inflicted. The penalty and award of damages were upheld.