Criminal Law

Melany Garin vs People of the Philippines

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G.R. No. 260021 – Criminal Law – Special Penal Laws – Anti-Child Abuse Law – Corporal Punishment in School

Melany Garin was a school teacher who, one day, ordered her pupils to place in their mouths pieces of trash, consisting of scraps of paper, pencil shavings, dirt, and candy wrappers from the classroom’s dustpan. AAA, one of the pupils, as a result of what Garin made him do, suffered lead poisoning and psychological trauma as certified by a psychiatrist.

ISSUE: What crime is Garin guilty of?

HELD: Garin is guilty of violating Republic Act No. 7610 or the Anti-Child Abuse Law. The act of Garin undoubtedly debased, degraded and demeaned the intrinsic worth and dignity of AAA. Garin’s deplorable act is manifestly prejudicial to AAA’s normal development, in light of his mental capacity and emotional maturity as a minor. The gravity of petitioner’s action becomes all the more pronounced considering that the incident occurred in class and by reason of her moral ascendancy as AAA’s teacher.

A person who commits an act that debases, degrades, or demeans the intrinsic worth and dignity of the child as a human being, whether habitual or not, can be held liable for violating RA 7610. While it may be true that not every instance of laying of hands on the child would constitute child abuse, Garin’s intention can be inferred from the manner in which she committed the act complained of. It bears stressing that coercion and intimidation is not a material element for an accused to be held culpable under this section (here, Garin used her ascendancy).

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