**Facts:**
1. **Incident and Complaint**:
– On September 2, 2000, Leonilo Sanchez alias Nilo arrived at VVV’s residence in Clarin, Bohol, looking for FFF, VVV’s father. In FFF’s absence, Sanchez ordered the family to vacate their home and began destroying their property.
– A violent altercation ensued, during which Sanchez is alleged to have hit VVV, a 16-year-old minor, three times with a piece of wood. As a result, VVV sustained contusions and hematomas.
2. **Procedural Posture**:
– **RTC Proceedings**:
– The Regional Trial Court (RTC) of Tagbilaran City initially heard the case. During the arraignment, Sanchez, through counsel, admitted to hitting VVV unintentionally.
– The RTC convicted Sanchez of violating Section 10(a), Republic Act No. 7610 and sentenced him to six to seven years and four months of prision mayor, along with monetary damages.
– **Appeal to the Court of Appeals (CA)**:
– Sanchez appealed the RTC decision, contesting the sufficiency of evidence, the alleged defect in the information, and the application of laws.
– The CA modified the RTC’s sentence by imposing an indeterminate penalty of six years and one day to eight years of prision mayor, but deleted the award of civil indemnity and damages while upholding the conviction.
– **Petition for Review to the Supreme Court**:
– Sanchez filed a petition for review on certiorari under Rule 45, contending errors in sustaining his conviction and asserting the information’s defectiveness. The Office of the Solicitor General (OSG) defended the convictions.
**Issues:**
1. Whether the RTC and CA erred in finding Sanchez guilty of the crime beyond a reasonable doubt.
2. Whether the Information charging Sanchez was defective for implying the acts complained of were not covered by the Revised Penal Code.
3. Whether the acts complained of constituted slight physical injuries under the Revised Penal Code rather than child abuse under R.A. No. 7610 and P.D. No. 603.
**Court’s Decision:**
1. **Guilt Beyond Reasonable Doubt**:
– The Supreme Court affirmed that the prosecution had established the elements of the offense. VVV’s direct and categorical testimony, corroborated by witnesses including her mother and medical evidence, substantiated the physical abuse. Sanchez’s denial was insufficient.
2. **Defective Information**:
– The Court ruled that the Information was not defective. The facts alleged therein—the minority of VVV, the acts of physical abuse, and their prejudicial impact on the child’s development—were explicit and covered under R.A. No. 7610 and P.D. No. 603.
3. **Child Abuse vs. Slight Physical Injuries**:
– The Court rejected the argument that the act constituted slight physical injuries under Article 266 of the Revised Penal Code. The assault on VVV, a minor, fell squarely within the ambit of child abuse as defined under R.A. No. 7610, given its harmful impact on her development.
**Doctrine:**
– Under R.A. No. 7610, “child abuse” includes physical abuse against minors, whether habitual or not. The law prescribes prision mayor in its minimum period for acts that are prejudicial to a child’s development.
– The rule in statutory construction is that “or” denotes dissociation and independence, implying multiple distinct punishable acts under Sec. 10(a) of R.A. No. 7610.
**Class Notes:**
– **Child Abuse (R.A. No. 7610, Presidential Decree No. 603)**:
– **Elements**:
– Victim is a minor.
– Physical or psychological maltreatment prejudicial to the child’s development.
– Covered by special laws, not necessarily by the Revised Penal Code.
– **Statutory Provisions**:
– Sec. 10(a) of R.A. 7610: Punishes child abuse with prision mayor in its minimum period.
– P.D. No. 603: Lists prohibited acts against children.
– **Indeterminate Sentence Law**:
– Applies to penalties derived from the Revised Penal Code even when enforced under special laws.
**Historical Background:**
– The case underscores the legislative intent behind R.A. No. 7610 to provide stronger protection for children, filling gaps in the Revised Penal Code and reflecting the 1987 Philippine Constitution’s mandate to safeguard children’s rights from all forms of abuse and exploitation. This legislation aims to ensure a comprehensive approach to the welfare and protection of minors.
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