
SUPREME COURT - SECOND DIVISION
[ G.R. No. 267315, April 02, 2025 ]
JAMES DUAVIT Y VILLACARLOS, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
Case Summary: Lascivious Conduct (R.A. 7610)
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- This case involves a teacher, James Duavit, who was convicted of two counts of lascivious conduct against his 15-year-old student, AAA. The Supreme Court affirmed the conviction, giving full weight to the victim's credible and consistent testimony, which was supported by a psychiatric diagnosis of Post-Traumatic Stress Disorder. The Court rejected the teacher's defense of denial and his attempts to discredit the victim by highlighting the victim's lack of physical resistance, emphasizing that a child's submission under the moral ascendancy of a teacher does not negate the crime.
- The Accused and Victim: James Duavit was the class adviser and teacher of the victim, AAA, who was 15 years old at the time of the incidents.
- First Incident (Dec. 12, 2014): After class, while alone with AAA in the classroom, Duavit locked the doors, talked about sex, and then held and touched AAA's penis despite his pleas to stop.
- Second Incident (Dec. 15, 2014): Again, Duavit isolated AAA in the classroom, locked the doors, and escalated the abuse by exposing and masturbating AAA's penis. He only stopped when another student passed by the room.
- Aftermath: AAA reported the incidents to his mother, who filed complaints. A psychiatrist later diagnosed AAA with Post-Traumatic Stress Disorder (PTSD) as a result of the abuse.
- RTC Ruling: The RTC found Duavit guilty of two counts of lascivious conduct under R.A. 7610. It gave full credence to AAA's straightforward and consistent testimony and highlighted Duavit's moral ascendancy as a teacher over a probationary student.
- Court of Appeals (CA) Ruling: The CA affirmed the conviction, upholding the trial court's assessment of the victim's credibility. It modified the penalties and increased the monetary awards for damages.
- Was the testimony of the minor victim, AAA, credible enough to sustain a conviction beyond a reasonable doubt?
- Did the prosecution successfully prove all the elements of lascivious conduct under Section 5(b) of R.A. 7610?
The Supreme Court DENIED the petition and AFFIRMED the conviction with modifications to the monetary awards.
- Victim's Testimony is Credible: The Court found AAA's testimony to be straightforward, convincing, and consistent. It rejected Duavit's attempts to discredit the victim by pointing out his failure to shout or escape, noting that there is no standard behavior for a victim of sexual abuse, especially a child under the influence of a person in authority.
- All Elements Proven: The prosecution successfully established all elements of the crime: (1) Duavit committed lascivious acts (touching and masturbating the victim's penis); (2) the victim was a child subjected to sexual abuse through Duavit's coercion and influence as a teacher; and (3) the victim was under 18.
- Penalties and Damages Modified: The Court affirmed the prison sentence but added a fine of PHP 15,000.00 and an award of PHP 50,000.00 in exemplary damages for each count of the offense, consistent with prevailing jurisprudence.
- Credibility of a Child Victim: The testimony of a child victim of sexual abuse is given great weight and can be sufficient for conviction if it is straightforward, convincing, and consistent. Corroboration is not essential.
- Moral Ascendancy and Influence: In cases under R.A. 7610, the "coercion or influence" of an adult can be established through moral ascendancy, such as that of a teacher over a student. Physical force is not required; the improper use of power that subdues the child's free will is sufficient.
- Victim's Behavior: A victim's failure to resist, shout, or escape is not an indication of consent and does not diminish their credibility. There is no standard reaction to sexual abuse.