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FELINA ROSALDES v. PEOPLE

FACTS:

In this case, the petitioner, a public schoolteacher, was charged with and found guilty of child abuse. The victim was her Grade 1 pupil, whom she physically maltreated after the child accidentally bumped her knee while she was asleep on a bamboo sofa in the classroom. The petitioner pinched the child's thigh, lifted him up by his armpits, and pushed him to the floor, causing him to lose consciousness. She then picked him up by his ears and repeatedly slammed him on the floor, causing physical injuries to the child. A physician certified the injuries sustained by the child. The petitioner was convicted by the Regional Trial Court and sentenced to an indeterminate prison term. On appeal, the Court of Appeals affirmed her conviction with a modification of the penalty. The petitioner then filed a petition for review on certiorari, raising issues on the nature of the offense and her right to due process.

The petitioner, who is a schoolteacher, was convicted of child abuse under Section 10(a) of Republic Act No. 7610. She inflicted physical injuries on her student, Michael Ryan, which resulted in the boy fainting. The petitioner argued that her actions were disciplinary and fell under the doctrine of in loco parentis, but the Family Code explicitly prohibits the infliction of corporal punishment by school administrators, teachers, or individuals exercising special parental authority. Dr. Teresita Castigador, the Medico-Legal Officer, provided evidence of the severe injuries sustained by the boy.

ISSUES:

  1. Whether the petitioner is guilty of child abuse for physically maltreating the victim.

  2. Whether the information charging the petitioner with child abuse is sufficient in form and substance.

  3. Whether the trial court and the appellate court committed an error in not granting civil damages as civil liability ex delicto.

  4. Whether the trial court and the appellate court erred in not prescribing the proper penalties and determining the civil liability to be imposed on the accused.

  5. Whether the Court of Appeals correctly imposed the indeterminate penalty of four years, two months and one day of prision correccional, as minimum, to 10 years and one day of prision mayor, as the maximum, on the ground that the offense was aggravated by the petitioner being a public schoolteacher

  6. Whether the revised penalty is correct under Section 10(a) of Republic Act No. 7610 which punishes the crime committed by the petitioner

RULING:

  1. Yes, the petitioner is guilty of child abuse. The medical report provided by the Medico-Legal Officer established the severe physical injuries sustained by the victim as a result of the petitioner's maltreatment. The trial judge and the Court of Appeals both concluded that the petitioner went overboard in disciplining the victim and that her actions degraded and demeaned the intrinsic worth and dignity of the child as a human being. The evidence presented proved beyond reasonable doubt that the petitioner was guilty of child abuse.

  2. Yes, the information charging the petitioner with child abuse is sufficient in form and substance. The information explicitly averred the offense of child abuse as defined in Section 3(b) of Republic Act No. 7610. It contained all the essential elements of the offense and complied with the requirements of Section 6, Rule 110 of the Rules of Court.

  3. Yes. Both the trial court and the appellate court committed an error in not granting civil damages as civil liability ex delicto. The child abuse inflicted physical and emotional trauma as well as moral injury on the victim, and it cannot be denied that his parents necessarily spent for his treatment. The lower courts had the authority to define and allow civil liability arising from the offense and fix their extent. The omission by the lower courts was a plain error that demands correction by the Court.

  4. Yes. The trial court and the appellate court disregarded their express mandate under Section 2, Rule 120 of the Rules of Court to prescribe the proper penalties and determine the civil liability to be imposed on the accused. The lower courts' failure to do so was a disregard of their duty and authority. The Court has the authority and duty to correct a matter of law and justice even if no appeal was filed. The lower courts' omission in prescribing the correct penalties and determining the civil liability must be corrected by the Court.

  5. The Court held that the Court of Appeals erred in revising the penalty imposed by the RTC. Section 10(a) of Republic Act No. 7610 punishes the crime committed by the petitioner with prision mayor in its minimum period, which ranges from six years and one day to six years and eight months. The maximum of the indeterminate sentence should come from the maximum period, which is seven years, four months and one day of prision mayor. The minimum of the indeterminate sentence should come from prision correccional in the maximum period, the penalty next lower than prision mayor in its minimum period, with a range of four years, two months and one day to six years.

PRINCIPLES:

  • The person exercising substitute parental authority has the same authority over the child as the parents and should not inflict corporal punishment on the child.

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

  • The sufficiency of an information should be challenged before the accused pleads to it and not at a later stage of the proceedings.

  • Courts should avoid omitting reliefs that the parties are properly entitled to by law or in equity under the established facts in their judgments in criminal cases.

  • Courts should prescribe the legal penalties and determine the civil liability ex delicto of the accused as mandated by the Rules of Court, unless the enforcement of the civil liability has been reserved or waived.

  • Moral damages should be awarded to assuage the moral and emotional sufferings of the victim.

  • Exemplary damages may be imposed if at least one aggravating circumstance attended the commission of the crime.

  • Temperate damages may be awarded when some pecuniary loss has been suffered but its amount cannot be proved with certainty.

  • Interest of 6% per annum shall be charged on all items of civil liability from the finality of the decision until full payment.

  • The penalty for child abuse is prescribed in Section 10(a) of Republic Act No. 7610.

  • The penalty to be imposed must be based on the provisions of the law applicable at the time of the commission of the offense.

  • The indeterminate sentence law provides for the imposition of an indeterminate sentence consisting of a minimum and maximum specified term of imprisonment for an offense.