SC caps dignity-violating discipline as child abuse
Abdiel Franz Bernales
Disciplining children will be considered child abuse if there is a clear intent to harm the child's dignity, according to the Supreme Court (SC) on January 9, 2025.
Section 10(a) of Republic Act No. 7610, also known as the Special Protection of Children Against Abuse, Exploitation, and Discrimination Act, applies to acts covered under the Revised Penal Code, as illustrated in the case against police officer San Juan, who was charged with inflicting psychological cruelty and emotional maltreatment on 15-year-old AAA by pointing a gun at the minor.
Any individual who commits acts of child abuse, cruelty, or exploitation or creates conditions detrimental to a child's development—including those outlined in Article 59 of Presidential Decree No. 603 (the Child and Youth Welfare Code), as amended, but not addressed under the Revised Penal Code—shall face the penalty of prison mayor in its minimum period.
This ruling aims to safeguard children from harmful disciplinary practices that demean their dignity while having a balance between respecting parental authority and preventing abusive actions that can cause physical, emotional, or mental harm.
In a decision penned by Associate Justice Jhosep Y. Lopez, the SC's Second Division upheld the conviction of a father for child abuse after subjecting his 12-year-old daughter and 10-year-old son to violent and excessive discipline.
Then the SC PIO said that "[t]he Supreme Court (SC) reiterated that disciplining children, even if it results in physical injuries, does not automatically amount to child abuse. For such to be considered abuse, there must be a clear intent to harm a child's dignity."
The High Court added that the parents' discipline measures for their children should not be "violent, excessive, or disproportionate to their misbehavior."
Also, the Regional Trial Court (RTC) and the Court of Appeals found the father guilty of violating Republic Act (RA) No. 7610, or the Special Protection of Children Against Abuse, Exploitation and Discrimination Act.
Under Section 3(b) of RA No. 7610, any act that debases, degrades, or demeans a child's dignity is considered child abuse.
It also stressed that if there is no intent to harm the child's dignity, the offender will not be liable for child abuse but can be charged with other crimes under the Revised Penal Code instead.
In this recent case ruling, SC's Second Division affirmed a lower court's decision finding a father guilty of violent and excessive discipline for his 12-year-old daughter and 10-year-old son.
The SC found that the father beat his children from 2017-2018, kicking his daughter, striking her with a wooden rod with a nail, pulling her hair, hitting his children with a dustpan, and cursing at them.
He argued that he disciplined his children "for misbehavior, such as failing to eat lunch and losing money from their coin banks."
However, the Regional Trial Court (RTC) and the Court of Appeals (CA) found the father guilty of violating Republic Act No. 7610 or the "Special Protection of Children Against Abuse, Exploitation and Discrimination Act."
Section 3(b) of the law defines child abuse as "[a]ny act by deeds or words which debases, degrades or demeans the intrinsic worth and dignity of a child as a human being."
The decision read that the "RTC opined that cursing and hitting a child with a wooden beater or dustpan is not the proper way to instill discipline", adding that spanking may harm the children physically, emotionally, and mentally.
In addition, the CA said that "all the elements of the crimes charged were present," emphasizing that the father's acts of spanking, kicking, and hurting his children with a dustpan "constituted physical abuse and cruelty which debased, degraded, and demeaned the intrinsic worth and dignity of his children."
"The father appealed to the SC, arguing that he had no intention of harming his children's dignity. However, the SC ruled that his actions went beyond reasonable discipline, showing a clear intent to harm the children's dignity," SC noted.
This led to the father's sentence of four to six years in prison, ordered to pay a fine worth P45,000 and P180,000 in damages for his children.