### Facts:
1. **Incident Date and Context**: On February 13, 1996, seven-year-old Michael Ryan Gonzales, a Grade 1 pupil at Pughanan Elementary School in Lambunao, Iloilo, accidentally bumped into his teacher, Felina Rosaldes, waking her from sleep.
2. **Immediate Reaction**: Rosaldes demanded an apology. When Michael did not comply and went to his seat, Rosaldes pinched his thigh, picked him up by his armpits, and pushed him to the floor, causing him to hit a desk and lose consciousness.
3. **Subsequent Actions**: Rosaldes continued to physically assault Michael, picking him up by his ears and slamming him to the floor repeatedly. Michael cried and later reported the incident to his mother during the lunch break, accompanied by two classmates.
4. **Medical Examination**: Michael was examined by Dr. Teresita Castigador, who documented several injuries: petechiae and tenderness on both ears, lumbar tenderness, contusions on the left thigh, and difficulty walking.
5. **Legal Proceedings Initiation**: The child’s family reported the incident to the Barangay Captain and the Police Station. An information was filed charging Rosaldes with violation of Section 10(a) of Republic Act No. 7610, the Child Abuse Law.
6. **Trial Court Decision**: On June 26, 2003, the Regional Trial Court (RTC) found Rosaldes guilty, sentencing her to four years, two months, and one day to six years and one day of imprisonment.
7. **Court of Appeals Decision**: On appeal, the Court of Appeals (CA) affirmed the conviction and modified the penalty to a higher range of four years, two months, and one day to ten years and one day.
8. **Appeal to Supreme Court**: In her petition for review, Rosaldes contended erroneous application of the child abuse law, violation of due process regarding the sufficiency of the information, and questioned her conviction based on the acts constituting child abuse under the applicable law.
### Issues:
1. **Nature of Acts Constituting Child Abuse**: Did Rosaldes’ actions constitute child abuse under Section 10(a) of RA 7610 or should they be penalized under the Revised Penal Code?
2. **Right to Due Process**: Did the information filed violate Rosaldes’ constitutional right to be informed of the nature and cause of the accusation?
### Court’s Decision:
1. **Legal Classification of Acts**:
– **Resolution**: The Supreme Court ruled that Rosaldes’ actions constituted child abuse under RA 7610. Her acts were unnecessarily violent and excessive for disciplining a child, debasing and demeaning the intrinsic worth of the child.
– **Doctrine Reiterated**: The Court cited Bongalon v. People, emphasizing that child abuse involves acts intended to debase or demean a child’s worth. Rosaldes’ conduct manifested intent to degrade Michael Ryan’s dignity.
2. **Due Process Argument**:
– **Resolution**: The Court found the information sufficient in form and substance. The essential elements of child abuse were adequately detailed in the charge, meeting the requirements under Rule 110, Section 6 of the Rules of Court.
3. **Civil Liability**:
– **Resolution**: The Supreme Court recognized the omission by the RTC and CA to award civil damages. The Court awarded moral, exemplary, and temperate damages totaling P60,000, plus interest as compensation for the physical and emotional trauma inflicted on Michael Ryan.
### Doctrine:
1. **Child Abuse under RA 7610 vs. Discipline**:
– Only acts intended to degrade or demean a child’s intrinsic worth and dignity qualify as child abuse under RA 7610.
– The Family Code explicitly prohibits corporal punishment by persons with substitute parental authority.
2. **Proper Form of Information and Due Process**:
– An information must state the offense, acts constituting the offense, the offended party, and other requisite details as per Rule 110, Section 6 of the Rules of Court.
### Class Notes:
– **Child Abuse (RA 7610)**:
– Acts intended to debase, degrade, or demean a child’s worth constitute child abuse.
– Legal penalty under Section 10(a) ranges from prision correccional to prision mayor.
– Elements of child abuse: intention to degrade a child’s dignity, physical or psychological harm.
– **Criminal Procedure**:
– Rule 110, Section 6 requires details on the nature of the offense, the accused, the acts ommitted, and the offended party for an information to be valid.
– Appeals on facts not entertained under Rule 45 unless exceptions apply.
### Historical Background:
The case is situated within the context of increasingly stringent legal protections for children’s rights in the Philippines. RA 7610, enacted in 1992, underscores the country’s serious stance against child abuse, exploitation, and discrimination. This case is indicative of the judiciary’s commitment to upholding these protections and ensuring that acts of violence against children are properly penalized and that victims receive appropriate redress.
The legal evolution reflects broader societal changes towards better child protection and the strengthening of legal measures to deter child abuse, reflecting the nation’s compliance with international child rights standards, particularly the United Nations Convention on the Rights of the Child (UNCRC), ratified by the Philippines in 1990.
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