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GONZALO A. ARANETA

FACTS:

Gonzalo Araneta y Alabastro was charged with violating the "Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act" based on an incident where he allegedly forcibly embraced a 17-year-old girl with the intent to abuse her sexually. During the trial, the prosecution presented testimonies from the victim, her sister, and their mother, who recounted the incident. The victim rejected the petitioner's advances, but he forced himself into their room, embraced her, and threatened her. The petitioner denied the charges and claimed that he did not embrace or kiss the victim. The RTC found the petitioner guilty and sentenced him to prision mayor in its minimum period, payment of moral damages, and costs. The petitioner appealed to the Court of Appeals, arguing that the prosecution failed to prove the elements of child abuse. The Office of the Solicitor General contended otherwise.

ISSUES:

  1. Whether proof of prejudice to the victim's development is an essential element of the crime of child abuse under Section 10(a) of Republic Act No. 7610.

  2. Whether the acts committed by the petitioner fall within the definition of child abuse under Section 10(a) of Republic Act No. 7610.

  3. Whether the act of forcibly hugging a minor and threatening her constitutes child abuse.

  4. Whether the penalty imposed by the Regional Trial Court is correct.

  5. Whether the award of moral damages is reasonable.

RULING:

  1. Proof of prejudice to the victim's development is not an essential element of the crime of child abuse under Section 10(a) of Republic Act No. 7610. An accused can be prosecuted and convicted under Section 10(a) if he commits any of the four acts mentioned therein, namely, child abuse, child cruelty, child exploitation, or being responsible for conditions prejudicial to the child's development. The prosecution is not required to prove that the acts of child abuse, child cruelty, and child exploitation have resulted in prejudice to the child's development because the act prejudicial to the child's development is different from those acts.

  2. The acts committed by the petitioner fall within the definition of child abuse under Section 10(a) of Republic Act No. 7610. The petitioner can be found guilty of child abuse if it is proven that he committed any of the four acts mentioned in Section 10(a), regardless of whether prejudice to the child's development occurred.

  3. Yes, the act of forcibly hugging a minor and threatening her constitutes child abuse. It debases, degrades, and demeans the intrinsic worth and dignity of the child as a human being. The act also violates the child's right to be protected from emotional maltreatment.

  4. The penalty of prision mayor in its minimum period imposed by the Regional Trial Court is correct, in accordance with Section 10(a), Article VI of Republic Act No. 7610.

  5. The award of moral damages in the amount of P50,000.00 is reasonable under the circumstances. Each case must be evaluated based on its peculiar facts, and the amount awarded should not be palpably and scandalously excessive.

PRINCIPLES:

  • Republic Act No. 7610 is a measure aimed at defending the rights of Filipino children and providing special protection against neglect, abuse, cruelty, exploitation, and other conditions prejudicial to their development. The law expands the definition of child abuse and provides stiffer penalties for its commission.

  • The four acts punishable under Section 10(a) of Republic Act No. 7610 are child abuse, child cruelty, child exploitation, and being responsible for conditions prejudicial to the child's development. Proof of prejudice to the child's development is not necessary for conviction under Section 10(a).

  • The word "or" in Section 10(a) of Republic Act No. 7610 signifies dissociation and independence of the four punishable acts. It does not qualify the three acts of child abuse, child cruelty, and child exploitation.

  • Child abuse includes any act that debases, degrades, or demeans the intrinsic worth and dignity of a child as a human being.

  • Unwanted physical contact with a minor can constitute child abuse.

  • The assessment of credibility of a witness by the trial court is entitled to great weight and is generally binding on appeal, unless there are overlooked or misinterpreted facts or circumstances of weight and substance.

  • The determination of moral damages is subjective and should be based on the particular facts of the case, taking into consideration that the amount awarded should not be palpably and scandalously excessive.