The Supreme Court (SC) Second Division has reaffirmed that excessively disciplining children in a manner that diminishes their dignity constitutes child abuse under the law.

In a decision penned by Associate Justice Jhosep Lopez, the Court emphasized that for an act to qualify as child abuse, there must be a clear intent to harm the child’s dignity. Physical injuries alone do not automatically constitute child abuse.

“As observed in these cases, when the infliction of physical injuries against a minor is done at the spur of the moment or intended to discipline or correct wrongful behavior, it is imperative that the specific intent to debase, degrade, or demean the intrinsic worth and dignity of the child as a human be established,” the decision stated.

Absent this specific intent, the offender may only be held liable for other crimes under the Revised Penal Code, provided all elements of those crimes are present, the Court clarified.

FACTS AND ISSUES

The case stemmed from incidents in 2017 and 2018 involving XXX, the father of minors AAA and BBB. In 2017, XXX physically abused AAA by pulling her hair, kicking her, and hitting her head. He also struck BBB with a dustpan handle on both sides of his body.

In a separate 2018 incident, XXX forced the children to lie down and spanked them with a plastic dustpan handle after becoming angry over their behavior. XXX justified his actions as disciplinary measures for their misbehavior.

The Regional Trial Court (RTC) convicted XXX of three counts of child abuse under Section 10(a) of Republic Act No. 7610, or the Special Protection of Children Against Abuse, Exploitation, and Discrimination Act. The RTC found XXX’s testimony inconsistent and unreliable.

Dissatisfied with the ruling, XXX appealed to the Court of Appeals (CA), which upheld the RTC’s decision. The CA found that the acts of spanking, kicking, and hitting the children with a dustpan, accompanied by verbal abuse, constituted physical and psychological cruelty, debasing their dignity as human beings.

RULING

The SC affirmed the CA’s decision, ruling that the father’s actions went beyond permissible disciplinary measures.

“His abusive acts may be considered as extreme measures of punishment not commensurate with the discipline of his 12-year-old and 10-year-old children. Given these circumstances, it can be reasonably inferred that his act of laying hands on his children was done with the specific intent to debase, degrade, or demean their intrinsic worth and dignity as human beings,” the decision read.

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