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Jeffrey Calaoagan vs. People of the Philippines

G.R. No. 222974 | March 20, 2019

FACTS:

On October 31, 2004 at around 12 midnight, Jeffrey Calaoagan was reported to have
physically maltreated complainants AAA and BBB, both minors. Such act is in contrary to Article
VI, Section 10(A) of the Republic Act 7610, otherwise known as “Special Protection of Children
Against Abuse, Exploitation and Discrimination Act”.

On November 5, 2012, the RTC ruled that Calaogan is guilty beyond reasonable doubt of
two (2) counts of Other Acts of Child Abuse. Aggrieved, Calaoagan filed for an appeal before the
Court of Appeals. In its February 9, 2016 Decision, the CA affirmed the petitioner’s conviction in
his case against AAA; and held that petitioner is also guilty if slight physical injuries in his case
against BBB.

Hence, this petition.

ISSUES:

Whether or not child abuse is present in this case.

RULING:

No, there is no child abuse.

It was ruled in this case and in previous landmark cases that Sec 10(A) of RA 7610 requires
an intent to debase, degrade, and demean the intrinsic worth of a child victim. Since the
prosecution failed to establish the existence of such element, the petitioner shall be only be liable
for the crime of slight physical injuries.

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