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JOEL C. JAVAREZ v. PEOPLE

FACTS:

Petitioner Joel Javarez was charged with violation of Section 10(a) in relation to Section 31(e) of Republic Act No. 7610 (RA 7610) under two separate Informations. In Criminal Case No. 24935, it was alleged that petitioner, while serving as a school teacher, committed physical abuse and cruelty upon a student named AAA. In Criminal Case No. 24936, it was alleged that petitioner hit another student named BBB with a broomstick. Both incidents were reported to the authorities, and the complainants underwent physical examination which showed injuries consistent with their allegations. Petitioner pleaded not guilty to both charges and claimed that the complainants fabricated the story against him. The trial court found petitioner guilty of child abuse and imposed the corresponding penalties. Petitioner appealed the decision to the Court of Appeals, which affirmed the trial court's ruling but modified the amount of damages awarded.

ISSUES:

  1. Did the Court of Appeals err in affirming petitioner's conviction for violation of RA 7610?

  2. Was petitioner liable under Section 10(a), Article VI of RA 7610?

  3. Whether the petitioner is liable under Section 10 (a), Article VI of RA 7610 for pushing AAA.

  4. Whether the petitioner is guilty of violation of Section 10 (a), Article VI, of RA 7610 and slight physical injuries under paragraph 2, Article 266, of the Revised Penal Code.

RULING:

  1. The petition is partly meritorious.

  2. Petitioner was not liable under Section 10(a), Article VI of RA 7610.

  3. The petitioner is not liable under Section 10 (a), Article VI of RA 7610 for pushing AAA.

  4. n Criminal Case No. 24936, the petitioner is found guilty of slight physical injuries under paragraph 2, Article 266, of the Revised Penal Code. He is sentenced to twenty (20) days of arresto menor. He is also ordered to pay BBB P5,000.00 moral damages which shall earn interest at the rate of six percent (6%) per annum from the date of finality of the decision until fully paid.

PRINCIPLES:

  • Under Section 3(b) paragraph 2 of RA 7610, child abuse may be committed by deeds or words which debase, degrade or demean the intrinsic worth and dignity of a child as a human being.

  • In order to be punished as child abuse, it must be shown beyond reasonable doubt that the accused laid his or her hands on the child with actual intent to debase, degrade, or demean the intrinsic worth and dignity of the child as a human being. Otherwise, it should be punished under the Revised Penal Code.

  • Debasement is the act of reducing the value, quality, or purity of something.

  • Degradation is the lessening of a person's or thing's character or quality.

  • Demeaning is to lower in character, status or reputation.

  • Acts committed out of instinct, lack of self-control, or emotional outrage may not have the specific intent required for the crime of child abuse.

  • For an accused to be held liable for physical injuries, there must be malicious intent to inflict such injuries.

  • A specific animus iniuriandi or malicious intention to do wrong against the physical integrity or well-being of a person is required for the commission of the crime of physical injuries.

  • When there is no evidence of actual incapacity of the offended party for labor or of the required medical attendance, the offense is only slight physical injuries.

  • Mere infliction of physical injuries, absent malicious intent, does not make a person automatically liable for an intentional felony.

  • The penalty for slight physical injuries is arresto menor, which ranges from one (1) day to thirty (30) days of imprisonment.

  • Moral damages may be recovered in a criminal offense resulting in physical injuries.

  • Violation of Section 10 (a), Article VI, of RA 7610 pertains to the act of committing child abuse, exploitation, and discrimination against a child.

  • Slight physical injuries under paragraph 2, Article 266, of the Revised Penal Code refers to the infliction of physical harm on another person resulting in physical pain or injury that requires medical treatment for nine days or less.

  • The imposition of arresto menor as a penalty is in accordance with the Revised Penal Code.

  • Moral damages may be awarded to compensate for the pain, anguish, and mental suffering experienced by the victim.