THE Supreme Court (SC) has held that parental disciplinary actions with clear intent to harm their children’s dignity is considered a form of child abuse.
This position is contained in a decision promulgated on July 22, 2024 but only made public yesterday, wherein the SC Second Division affirmed the conviction of a father for child abuse after subjecting his 12-year-old daughter and 10-year-old son to violent and excessive disciplinary acts.
In the ruling penned by Associate Justice Jhosep Lopez, the High Court held that the actions of the accused father went beyond reasonable discipline and showed a clear intent to harm his children’s dignity.
Records of the case showed that from 2017 to 2018, the father beat his children, including kicking his daughter, pulling her hair, striking her with a wooden rod with a nail, hitting them with a dustpan, and cursing at them repeatedly.
Brought before the regional trial court, the father pleaded not guilty during his arraignment and justified that his actions were meant to discipline his children for misbehavior, such as failing to eat lunch and losing money from their coin banks.
The trial court and the Court of Appeals both found the father guilty of violating Republic Act 7610, or the Special Protection of Children Against Abuse, Exploitation and Discrimination Act.
Under Section 3(b) of the said law, any act that debases, degrades, or demeans a child’s dignity is considered child abuse.
The father appealed his conviction to the SC, arguing that he had no intention of harming his children’s dignity.
The High Court denied his appeal and affirmed the lower court’s and CA’s decisions.
The SC ruled that while parents have the right to discipline their children, such measures must not be violent, excessive, or disproportionate to their misbehavior.
It clarified, though, that offenders cannot be held liable for child abuse but can be charged with other crimes under the Revised Penal Code if there was no clear intent that they wanted to harm their victim’s dignity.
.“This Court emphasized that only when the laying of hands is shown beyond reasonable doubt to be intended by the accused 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 Revised Penal Code,” the SC said.
With this, the High Court affirmed the father’s conviction and sentence of four to six years in prison and fine of P45,000.
He was also ordered to pay his children P180,000 in damages.
Senior Associate Justice Marvic Leonen and Associate Justices Mario Lopez, Amy Lazaro Javier and Antonio Kho Jr. concurred with the decision.
