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    People vs. Patulot - Case Digest

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    Gendale Am-is
    The document summarizes a Supreme Court case from the Philippines regarding child abuse. The case discusses whether intent to degrade a child needs to be proven for a child abuse charge. The Court ruled that intent to degrade does not need to be proven, as child abuse and other acts under the law are distinct offenses with different elements.

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    People vs. Patulot - Case Digest

    Uploaded by

    Gendale Am-is
    226 views5 pages
    The document summarizes a Supreme Court case from the Philippines regarding child abuse. The case discusses whether intent to degrade a child needs to be proven for a child abuse charge. The Court ruled that intent to degrade does not need to be proven, as child abuse and other acts under the law are distinct offenses with different elements.

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    People vs. Patulot

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    People vs. Patulot_Case Digest

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    The document summarizes a Supreme Court case from the Philippines regarding child abuse. The case discusses whether intent to degrade a child needs to be proven for a child abuse charge. The Court ruled that intent to degrade does not need to be proven, as child abuse and other acts under the law are distinct offenses with different elements.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    226 views5 pages

    People vs. Patulot - Case Digest

    Uploaded by

    Gendale Am-is
    The document summarizes a Supreme Court case from the Philippines regarding child abuse. The case discusses whether intent to degrade a child needs to be proven for a child abuse charge. The Court ruled that intent to degrade does not need to be proven, as child abuse and other acts under the law are distinct offenses with different elements.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 5

    Stare Decisis

    Updates, news, insights, articles and digests on Supreme Court Cases


    and things related to law

    CRIMINAL LAW, LAW REVIEW, PHILIPPINE SUPREME


    COURT DECISIONS (CASE DIGESTS), UNCATEGORIZED

    [2019 CASE DIGEST]


    Evangeline Patulot vs. People
    of the Philippines G.R. No.
    235071, January 07, 2019

    Date: March 7, 2019 0 Comments


    FACTS:
    As she was about to enter the house, CCC, after gathering
    https://staredecisis101.wordpress.com/2019/03/07/case-dige…s-people-of-the-philippines-g-r-no-235071-january-07-2019/ 07/03/2019, 7C18 PM
    clothes from the clothesline outside her house, was surprised to Page 1 of 5

    see Patulot who was holding a casserole. Without warning,


    Patulot poured the contents of the casserole – hot cooking oil –
    on her. AAA and BBB, both minors, who were nearby, suddenly
    cried because they were likewise hit by the hot cooking oil.
    CCC hurriedly brought AAA and BBB to her three neighbors
    who volunteered to bring the children to the hospital, for
    treatment. She then went to the barangay hall also at South
    Signal, Taguig City, to report the incident.

    The doctor, who examined and treated CCC and her children,
    testified that the injuries suffered by AAA and BBB would heal
    for an average period of thirty (30) days. Next, DDD testified
    that he incurred P7,440.00 in medical expenses for his wife and
    children.

    The Regional Trial Court found Patulot guilty of child abuse


    under R.A. 7610.

    The CA affirms Patulot’s conviction.

    Aggrieved, Patulot elevated the case to the Supreme Court,


    invoking the following arguments:

    She (Patulot) can only be convicted of physical injuries and not


    child abuse. Citing the case, Bongalon v. People, she submits that
    not every instance of laying hands on a child constitutes the
    crime of child abuse under Section 10(a) of R.A. No. 7610.
    Only when the laying of hands is shown to be intended to
    debase, degrade, or demean the intrinsic worth and dignity of
    the child as a human being should it be punished as child
    abuse. Otherwise, it is punished under the RPC. Thus, in the
    absence of such intention on the part of Patulot, her true
    intention being to pour hot oil only on CCC with AAA and BBB
    being merely accidentally hit, she cannot be convicted of child
    abuse.

    ISSUE:

    Is there a need to prove that the acts where intended to debase,


    degrade, or demean the intrinsic worth and dignity of the child
    as a human being should it be punished as child abuse?

    RULING:

    NO.

    Patulot contends that on the basis of our pronouncement


    in Bongalon, she cannot be convicted of child abuse because it
    was not proven that she intended to debase, degrade, or
    demean the intrinsic worth and dignity of AAA and BBB as
    human beings. Her reliance on said ruling, however, is
    misplaced. In Bongalon, the Information specifically charged
    George Bongalon, petitioner therein, of committing acts which
    “are prejudicial to the child’s development and which demean
    the intrinsic worth and dignity of the said child as a human
    being.”Thus, we ruled that he can only be held liable for slight
    physical injuries instead of child abuse in the absence of proof
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    Page 2 of 5
    that he intended to humiliate or “debase the ‘intrinsic worth
    and dignity'”of the victim.

    A cursory review of the Informations in the instant case,


    however, reveals no similar allegation that Patulot’s acts
    debased, degraded, or demeaned the intrinsic worth and
    dignity of AAA and BBB as human beings. Instead, they
    charged Patulot for willfully committing acts of child abuse on
    AAA and BBB “by throwing on them boiling oil, thereby
    inflicting upon said victim-minor physical injuries, which acts
    are inimical and prejudicial to the child’s normal growth and
    development.”
    There are distinct acts punishable under R.A. No. 7610, to wit:
    (a) child abuse, (b) child cruelty, (c) child exploitation and (d)
    being responsible for conditions prejudicial to the child’s
    development.

    R.A. No. 7610 and its Rules and Regulations distinctly and
    separately defined child abuse, cruelty and exploitation just to
    show that these three acts are different from one another and
    from the act prejudicial to the child’s development. Contrary to
    Patulot’s assertion, an accused can be prosecuted and be
    convicted under Section 10(a), Article VI of Republic Act No.
    7610 if he commits any of the four acts therein. The prosecution
    need not prove that the acts of child abuse, child cruelty and
    child exploitation have resulted in the prejudice of the child
    because an act prejudicial to the development of the child is
    different from the former acts.

    Neither can Patulot argue that in the absence of intention on


    her part to harm AAA and BBB, she cannot be convicted of
    child abuse because she merely intended on committing
    physical injuries against CCC.

    “When the acts complained of are inherently immoral, they


    are deemed mala in se, even if they are punished by a special
    law. Accordingly, criminal intent must be clearly established
    with the other elements of the crime; otherwise, no crime is
    committed.”

    The petitioner was convicted of violation of Section 10(a),


    Article VI of R.A. No. 7610, a special law. However, physical
    abuse of a child is inherently wrong, rendering material the
    existence of a criminal intent on the part of the offender.

    Patulot’s criminal intent is not wanting for as she expressly


    admitted, she intended on pouring hot cooking oil on CCC. As
    such, even granting that it was not her intention to harm AAA
    and BBB, she was performing an unlawful act when she threw
    the hot oil from her casserole on CCC. She cannot, therefore,
    escape liability from the same in view of the settled doctrine
    that a person incurs criminal liability although the wrongful
    act done be different from that which he intended.

    ANNOTATIONS:
    https://staredecisis101.wordpress.com/2019/03/07/case-dige…s-people-of-the-philippines-g-r-no-235071-january-07-2019/ 07/03/2019, 7C18 PM
    Page 3 of 5
    In this case, we learned two (2) things:

    1. There are four (4) distinct acts punished under 7610,


    namely:
    2. child abuse, (b) child cruelty, (c) child exploitation and (d)
    being responsible for conditions prejudicial to the child’s
    development
    3. The prosecution need not prove that the acts of child abuse,
    child cruelty and child exploitation have resulted in the
    prejudice of the child because an act prejudicial to the
    development of the child is different from the former acts.
    Therefore, if the accused is charged of Child Abuse, Child
    Cruelty, or Child Exploitation, there is no need to prove that
    these acts are prejudicial to the development of the child. But if
    the Information charged the accused of “acts prejudicial to the
    child’s development and which demean the intrinsic worth and
    dignity of the said child as a human being” (as in the case of
    Bongalon), then, there is a need for the prosecution to prove
    that, indeed, the acts are prejudicial to the development of the
    child, otherwise, the accused could only be found guilty of the
    lower offense of physical injury.

    Read Full Text: Evangeline Patulot vs. People of the Philippines


    G.R. No. 235071, January 07, 2019

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