### Facts:
– **November 28, 2015:** CCC, the mother of the minor victim AAA, hosted a birthday party at their house. Jan Victor Carbonell y Ballesteros, the then-boyfriend of AAA’s older sister BBB, attended the party.
– **During the party:** Carbonell entered AAA’s room, locked the door, and told her he might have impregnated BBB. To help him, AAA gave Carbonell contraceptive pills suggesting he give them to BBB.
– **Demand and assault:** Carbonell threatened to ruin AAA’s reputation by telling her friends she had contraceptive pills if she did not comply. Under this threat, AAA removed her shirt, and Carbonell mashed her breast. AAA pushed him out of her room.
– **December 2015:** AAA learned that Carbonell was spreading false rumors about her. She then disclosed the incident to her mother, CCC.
– **Legal Actions:** CCC and AAA filed a criminal complaint against Carbonell.
### Procedural Posture:
1. **Regional Trial Court (RTC):** Carbonell was charged and found guilty of Acts of Lasciviousness under Article 336 of the Revised Penal Code (RPC). Sentence: 6 months arresto mayor to 4 years and 2 months prision correctional plus damages.
2. **Court of Appeals (CA):** Modified the RTC’s decision and convicted Carbonell under Section 5(b), Article III of Republic Act (R.A.) No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act). Sentence: 10 years and 1 day of prision mayor to 17 years, 4 months, and 1 day of reclusion temporal plus damages.
3. **Supreme Court:** The case was elevated to the Supreme Court via a Petition for Review on Certiorari under Rule 45, contesting the CA’s conviction due to alleged testimonial inconsistencies and asserting defense of denial.
### Issues:
1. **Credibility of AAA’s Testimony:** Whether the court correctly affirmed AAA’s testimony despite inconsistencies between her affidavit and court statements.
2. **Proof Beyond Reasonable Doubt:** Whether the prosecution established Carbonell’s guilt beyond reasonable doubt.
3. **Defense of Denial:** Whether the court erred in disregarding Carbonell’s defense of denial.
### Court’s Decision:
– **Credibility of Testimony:** The Supreme Court upheld the RTC and CA’s decisions, giving paramount weight to the consistency and straightforwardness of AAA’s testimony. Minor inconsistencies did not detract from her overall credibility.
– **Proof Beyond Reasonable Doubt:** The Court found that the prosecution effectively established Carbonell’s guilt. It accepted AAA’s account of the events, corroborated by the threat and intimate conduct involved.
– **Defense of Denial:** The Court rejected Carbonell’s uncorroborated denial, deeming it weaker than the positive identification and detailed testimony provided by AAA.
### Doctrine:
– **Children as Credible Witnesses:** Courts give credence to the testimonies of child witnesses, recognizing that their youth and immaturity often reflect truthfulness and sincerity.
– **Application of R.A. No. 7610 over RPC:** For cases involving minors, R.A. No. 7610 takes precedence in providing stricter penalties.
– **Non-Caption-Based Conviction:** The facts alleged in the Information, rather than the caption, control the determination of the offense.
### Class Notes:
– **Elements of Acts of Lasciviousness (RPC Article 336):**
1. Act of lasciviousness or lewdness.
2. Done under specific circumstances.
3. Involves another person of either sex.
– **Elements of Lascivious Conduct (R.A. No. 7610, Section 5(b)):**
1. Act of sexual intercourse or lascivious conduct.
2. Performed with a child exploited in prostitution or subjected to other sexual abuse.
3. Victim is below 18 years of age.
– **Relevant Statute:**
– R.A. No. 7610 – Special Protection of Children Against Abuse, Exploitation and Discrimination Act.
### Historical Background:
– **Child Protection Focus:** The case illustrates the legislative focus on stricter penalties for crimes against minors, pursuant to R.A. No. 7610. This Act was put in place to offer stronger protection to children against various forms of abuse and exploitation, reflecting a significant shift in societal and legal views on child welfare and protection.
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