The Supreme Court (SC) has warned parents of imprisonment and payment of damages if they go overboard in disciplining their children by inflicting physical injuries or hurling verbal abuses due to trivial matters.
In a decision, the SC reminded parents that while they have the right to instill discipline on their minor children, the disciplinary measures “must not be excessive, violent, and completely disproportionate” to correct the alleged misconduct or misbehavior of their children.
To impose excessive and violent actions to instill discipline on children can be considered as “specific intents to debase, degrade, or demean their intrinsic worth and dignity as human beings.”
Under Section 3(b) of Republic Act No. 7610, the Special Protection of Children Against Abuse, Exploitation and Discrimination Act, “child abuse” refers “to the maltreatment, whether habitual or not, of the child which includes, among other acts, “psychological and physical abuse, neglect, cruelty, sexual abuse and emotional maltreatment; any act by deeds or words which debases, degrades or demeans the intrinsic worth and dignity of a child as a human being; unreasonable deprivation of his basic needs for survival, such as food and shelter; or failure to immediately give medical treatment to an injured child resulting in serious impairment of his or her growth and development or in his or her permanent incapacity or death.”
Thus, the SC pointed out that “child abuse may be committed by deeds or words which debase, degrade, or demean the intrinsic worth and dignity of a child as a human being.”
The SC decision, which was made public on Thursday, Jan. 9, and written by Associate Justice Jhosep Y. Lopez, affirmed the conviction of a father (whose name was redacted in the decision) for child abuse and the prison term imposed on him by both the trial court and the Court of Appeals (CA).
In dismissing the appeal of the father, the SC said that “he went overboard in discipling his children when he inflicted upon them physical injuries due to trivial matters.”
The SC also said: “Hitting AAA (the 12-year-old daughter) several times with a wooden rod embedded with a nail was certainly not commensurate or reasonably necessary to discipline her just because she had not eaten her lunch.
“In the same vein, petitioner (the father) used excessive force when he pulled AAA's hair, kicked, and hit her head, and struck BBB (the 10-year- old son) with a dustpan multiple times just because the money saved in their coin banks was lacking.
“Although petitioner, as a parent, has the right to instill discipline on his minor children, still, the disciplinary measures he employed in this case were excessive, violent, and completely disproportionate to correct the alleged misconduct or misbehavior of his children.
“His abusive acts may be considered as extreme measures of punishment not commensurate to 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.
“On this score, the CA did not err in affirming petitioner's guilt beyond reasonable doubt for three counts of child abuse under Section l0(a) of Republic Act No. 7610.”
Section 10(a) of RA 7610 on other acts of “Neglect, Abuse, Cruelty or Exploitation and Other Conditions Prejudicial to the Child's Development” provides that “any person who shall commit any other acts of child abuse, cruelty or exploitation or to be responsible for other conditions prejudicial to the child's development including those covered by Article 59 of Presidential Decree No. 603, as amended, but not covered by the Revised Penal Code, as amended, shall suffer the penalty of prision mayor in its minimum period.”
The dispositive portion of the decision:
“Accordingly, the Petition is dismissed. The Nov. 22, 2022 Decision and June 27, 2023 Resolution of the Court of Appeals in CAG.R. CR No. 45863 are affirmed.
“In Criminal Case Nos. 4556-M-2018 to 4558-M-2018, petitioner is found guilty beyond reasonable doubt of three counts of child abuse under Section l0(a) of Republic Act No. 7610 and he is sentenced to suffer the indeterminate penalty of four years, nine months, and 11 days of prision correccional, as minimum, to six years, eight months, and one day of prision mayor, as maximum, for each count. He is likewise ordered to pay a fine of P15,000 for each count.
“He is further ordered to pay private complainants AAA and BBB the amount of P20,000 as moral damages, P20,000 as exemplary damages, and P20,000 as temperate damages for each count of child abuse.
“Lastly, all the monetary awards shall earn six percent interest per annum from the date of finality of this Decision until fully paid. So ordered.”