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Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.
AT A GLANCE:
In the recent case of XXX v. People (G.R. No. 268457) the Supreme Court held that when the infliction of physical injuries against a minor is done at the spur of the moment or intended to discipline or correct the wrongful behavior of the child, it is imperative that the specific intent to debase, degrade, or demean the intrinsic worth and dignity of the child as a human be established.
XXX, the father of the minor victims AAA and BBB was charged with child abuse in three separate Informations.
In 2017, XXX asked AAA if she had already eaten lunch and when she answered in the negative, XXX got angry and hit her with a wooden rod embedded with a nail. In 2018, XXX found out that the money saved in his children’s coin banks were lacking, he threw the coin banks at them and proceeded to pull out AAA’s hair, kicked her, and hit her head. He also struck BBB with the handle of a dustpan.
XXX denied the accusations hurled against him and claimed that he only scolded his children for misbehavior, such as failing to eat lunch and losing money from their coin banks.
The Regional Trial Court (RTC) found XXX guilty of three counts of child abuse under Republic Act No. 7610, or the Special Protection of Children Against Abuse, Exploitation and Discrimination Act. The RTC gave due weight and credit to the testimonies of the victims. It opined that cursing and hitting a child with a wooden beater or dustpan is not the proper way to instill discipline. On appeal, the CA affirmed the RTC’s decision
Issue: Whether the guilt of XXX for child abuse was proven beyond reasonable doubt.
The Supreme Court’s Decision:
Yes. The Supreme Court found XXX guilty beyond reasonable doubt of three (3) counts of child abuse.
Under Section 3(b) of R.A. No. 7610, child abuse refers to the maltreatment, whether habitual or not, of the child which includes any act by deeds or words which debases, degrades or demeans the intrinsic worth and dignity of a child as a human being.
Jurisprudence dictates that when the infliction of physical injuries against a minor is done at the spur of the moment or intended to discipline or correct the wrongful behavior of the child, it is imperative that the specific intent to debase, degrade, or demean the intrinsic worth and dignity of the child as a human be established. In the absence of this specific intent, the offender cannot be held liable for child abuse but only for other crimes punishable under the RPC, provided that all the elements of the latter are present.
The Supreme Court held that XXX committed acts that debased, degraded, or demeaned the intrinsic worth and dignity of the private complainants as human beings. There is no dispute that AAA and BBB were both minors at the time of the commission of the crimes. Through their testimonies, it was sufficiently established that XXX physically assaulted them on two different occasions.
According to the Court, XXX went overboard in disciplining his children when he inflicted upon them physical injuries due to trivial matters. Although XXX, as a parent, has the right to instill discipline on his minor children, still, the disciplinary measures he employed in this case were excessive, violent, and completely disproportionate to correct the alleged misconduct or misbehavior of his children.
Ultimately, the Supreme Court ruled that the abusive acts committed by XXX may be considered as extreme measures of punishment not commensurate to the discipline of his 12-year-old and 10-year-old children.
Source:
XXX vs. People of the Philippines
G.R. No. 268457 | July 22, 2024
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