The Supreme Court (SC) upheld the Juvenile Justice and Welfare Act and ruled that children in conflict with the law must be penalized with due regard to their minority, even in serious offenses.

In a decision penned by Associate Justice Mario V. Lopez, the Court En Banc underscored the necessity of applying restorative justice principles to minor offenders as it affirmed the statutory rape conviction of a minor while reducing the penalty to reclusion temporal. 

“The enactment of Republic Act No. 9346 in 2006 resulted in the statutory interdiction of the death penalty… As such, ‘death’ as a penalty in Article 71 is no longer part of the equation for graduation of penalties,” the ruling wrote.

FACTS AND ISSUE

The case involves a 15-year-old minor accused of the statutory rape of a five-year-old girl in Laguna in December 2014.

The prosecution established the minor’s guilt through the victim’s testimony and medical evidence, while the accused presented an alibi and argued that the victim’s intact hymen created reasonable doubt regarding carnal knowledge.

The Regional Trial Court (RTC) initially convicted the minor and ordered a suspended sentence, but the Court of Appeals later affirmed the conviction and modified the penalty to reclusion perpetua.

The main issue brought before the SC was whether the prosecution proved the minor’s guilt beyond reasonable doubt and how the penalty should be correctly graduated considering the accused’s status as a CICL and the statutory abolition of the death penalty.

THE RULING

The SC denied the appeal and affirmed the conviction of CICL XXX265302, but it reduced the penalty to reclusion temporal and increased the total damages awarded to the victim to PHP 450,000.00.

The Court ruled that because the death penalty has been abolished by Republic Act No. 9346, the baseline for graduation must start from reclusion perpetua, requiring the penalty for a minor to be lowered by one degree.

“This Court’s primary consideration in cases involving children in conflict with the law is to give life to the policy of the State to provide them with the necessary assistance and to foster their development.”

The Court further ordered the remand of the case to the RTC for appropriate disposition in accordance with Section 51 of Republic Act No. 9344, or the Juvenile Justice and Welfare Act of 2006.

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