January 2025

Facts On March 26, 2014, a drunk Marvin L. San Juan willfully, unlawfully and feloniously threatened the life of AAA, a fifteen year old child, by poking a gun at him without any justifiable cause. This act amounts to a crime, thereby subjecting the minor to psychological cruelty and emotional maltreatment. San Juan argued that he cannot be held liable for child abuse because the information did not allege, nor was his intention to debase, degrade, or demean the intrinsic worth and dignity of AAA proven in trial. ISSUE: Can the accused be held guilty of child abuse? With respect to the act of child abuse, Section 3(b) of R.A. No. 7610 provides: Ruling It is a general rule that if it is proved that the accused committed the unlawful act charged, it will be presumed that the act was done with a criminal intention, and that it is for the accused to rebut this presumption. However, there are certain crimes of which a specific intent to accomplish a particular purpose is an essential element. This specific intent was taken into consideration by this Court in the analysis of crimes involving violation of Section 3(b)(2) of R.A. No. 7610. Pointing a firearm towards a minor is intrinsically cruel. “Certainly, the term cruelty, in its common usage, simply means suffering that is excessive and unnecessary to the purpose to be achieved by an offender. An act that is accompanied by such a cruel act can easily be determined by the manner it was executed. It does not need an inquiry into the specific intent to debase, degrade or demean the intrinsic worth and dignity of the child, as being referred to under the Rules and Regulations of R.A. No. 7610. “ When the act itself is examined based on the inherent characteristic of the act itself and the manner of its execution, and it later turns out to be intrinsically cruel, there should be no need to look into the specific intent. Again, the term cruelty, when not qualified by the terms “to debase, degrade or demean the intrinsic worth and dignity of the child,” may still be utilized based on its common usage.

Facts Miguel Aquino had three sons: Arturo, Rodolfo, and Abbulah. Arturo and a woman named Maria Angela Kuan Ho had relations, resulting in the birth of Angela Aquino, their illegitimate child. Maria and Arturo also had plans to get married. Sadly, Arturo passed away on January 10, 1999, before Angela was born and before he and Maria could officially marry. Though Maria and Arturo never got married, Miguel treated his granddaughter very fondly. In fact, he paid for all of Maria’s expenses during her pregnancy and had Angela live with the Aquinos in their ancestral home. Angela’s uncles, Rodolfo and Abbulah, were also quite fond of her, and Rodolfo was made to be one of Angela’s godfathers. Things changed drastically after Miguel’s death. Upon settlement of his estate, it was found that Angela was included among the heirs who would receive portions of the estate. Her uncles, Rodolfo and Abbulah, opposed this. This is because according to them: ISSUE: Can an illegitimate child inherit from his/her direct ascendants? YES. Children, regardless of their circumstances at birth, are QUALIFIED to inherit from their direct ascendants. There was no specification in the term “grandchildren” whether only legitimate children are allowed to inherit from their grandparents, so there was no need to qualify, much less restrict, the application to only legitimate grandchildren. It is unfair for an illegitimate child to be placed in an unfair situation wherein he/she is only inheriting half as much as his/her legitimate counterparts. The ponencia did away with the terms “illegitimate” and “legitimate” when referring to children based on their parent’s status. Instead, Justice Leonen used the terms “marital” and “nonmarital” children.

Facts Grace Poe was found abandoned as a newborn infant in the Parish Church of Jaro, Iloilo in 1968. At age 5, she was adopted by celebrity spouses Fernando Poe, Jr. and Susan Roces. She initially pursued a degree in Developmental Studies at the University of the Philippines but opted to continue her studies abroad and left for the U.S. in 1988. She immigrated to the U.S. in 1991 after her marriage to Theodore Llamanzares, who was based in the U.S. at the time. In 2001, she became a naturalized American citizen. In 2004, Grace Poe returned to the Philippines to support her father’s candidacy for President. After her father’s death, she and her husband decided to reside permanently in the Philippines in 2005. On 7 July 2006, Grace Poe took her Oath of Allegiance to the Republic of the Philippines pursuant to the Citizenship Retention and Re-acquisition Act of 2003. The BI declared that she is deemed to have reacquired her Philippine citizenship while her children are considered as citizens of the Philippines. Consequently, the BI issued Identification Certificates (ICs) in her name and in the names of her three children. In 2010, President Benigno S. Aquino III appointed Grace Poe as Chairperson of the Movie and Television Review and Classification Board (MTRCB). Before assuming her post, she executed an “Affidavit of Renunciation of Allegiance to the United States of America and Renunciation of American Citizenship” before a notary public in Pasig City on 20 October 2010, in satisfaction of the legal requisites stated in Section 5 of R.A. No. 9225. The following day, she submitted the said affidavit to the BI and took her oath of office as Chairperson of the MTRCB. From then on, Grace Poe stopped using her American passport. On 2 October 2012, she filed with the COMELEC her Certificate of Candidacy (COC) for Senator for the 2013 Elections wherein she answered “6 years and 6 months” to the question “Period of residence in the Philippines before May 13, 2013.” She obtained the highest number of votes and was proclaimed Senator on 16 May 2013. On 15 October 2015, Grace Poe filed her COC for the Presidency for the May 2016 Elections. In her COC, Grace Poe declared that she is a natural-born citizen and that her residence in the Philippines up to the day before 9 May 2016 would be ten (10) years and eleven (11) months counted from 24 May 2005. Her filing of her COC for President in the upcoming elections triggered the filing of several COMELEC cases against her which were the subject of these consolidated cases. These cases argued that Grace Poe cannot be considered as a natural-born Filipino on account of the fact that she was a foundling, and that international law does not confer natural-born status and Filipino citizenship on foundlings. They also argued that she fell short of the ten-year residency requirement of the Constitution as her residence could only be counted at the earliest from July 2006, when she reacquired Philippine citizenship under the said Act. Issue ISSUE 1: Should Grace Poe be considered a natural-born Filipino citizen? YES. Grace Poe’s blood relationship with a Filipino citizen is DEMONSTRABLE. To deny full Filipino citizenship to all foundlings and render them stateless just because there may be a theoretical chance that one among the thousands of these foundlings might be the child of not just one, but two, foreigners is downright discriminatory, irrational, and unjust. ISSUE 2: Does Grace Poe satisfy the 10-year residency requirement of the Constitution? YES. Grace Poe’s claim that she will have been a resident for ten (10) years and eleven (11) months on the day before the 2016 elections, is true. This period of residence corresponds to a beginning date of 25 May 2005 when she returned for good from the U.S. Ruling The petition was thus GRANTED. GRACE POE is DECLARED QUALIFIED to be a candidate for President in the National and Local Elections of 9 May 2016.