8/6/25, 10:07 PM People vs.
YYY
Title
People vs. YYY
Case Decision Date
G.R. No. 262941 Feb 20, 2024
YYY was convicted for child pornography involving her niece, utilizing a computer
system to exploit minors, leading to a harsh sentence and fines.
Jur.ph - Case Digest (G.R. No. 262941)
Expanded Legal Reasoning Model
Facts:
Antecedents
July 13, 2016 – FBI traced accused’s emails, discovered nude photos of minor girls
for sale, identified location in Angeles City, Pampanga; undercover chat ensued
where accused offered child pornography and proposed sexual meet-up.
July 27, 2016 – US Embassy Legal Attaché informed PNP; PNP’s Col. Tuliao tasked
PSI Gallano to verify report; surveillance on August 6, 2016 found minor girls, a
computer with webcam, vibrator, children’s panties matching FBI photos.
Search Warrant and Execution
August 11, 2016 – Col. Tuliao applied for warrant before RTC Judge Pamular,
supported by surveillance reports and FBI letter; warrant described house address
and 17 categories of items (computers, storage devices, sex toys, clothing, receipts,
vehicle).
August 16, 2016 – Police and barangay officials served warrant; inventoried ECS-
marked items (computer set, modem, receipts, vibrator, cellphone, clear book, etc.);
rescued three minors (AAA, BBB, CCC) and turned them over to DSWD.
Investigation, Trial and Appeals
Digital forensic exam retrieved nude images/videos of AAA and chat logs about sale;
interviews with AAA recounted forced nudity and sexual acts before the webcam.
September 2017 – Information filed for violations of RA 9775 §§ 4(a),(b),(c) in
relation to § 16, and RA 10175 § 4(c)(2); accused pleaded not guilty, claimed
fabrication and illegal entry.
July 9, 2020 – RTC convicted accused of child pornography with use of computer,
sentenced to reclusion perpetua, fined ₱2,000,000, awarded moral (₱50,000) and
exemplary (₱100,000) damages.
February 28, 2022 – CA affirmed conviction, held Information date allegation and
search warrant valid; denied accused’s claims of defect and illegality in search.
Issues:
Evidence and Credibility
Whether the minor victim’s testimony and digital evidence sufficiently proved
elements of child pornography.
Whether accused’s denial defense undermines conviction.
Information and Warrant
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Whether the Information was defective for lack of precise date.
Whether the search warrant was validly issued and executed.
Repeal of RA 9775
Whether the enactment of RA 11930, which repealed RA 9775 without a saving
clause but reenacted similar offenses, extinguished criminal liability.
Ruling:
Repeal with Reenactment
RA 11930’s express repeal of RA 9775 is neutralized by simultaneous reenactment of
child pornography offenses; pending liability unaffected.
Conviction Affirmed
All elements under RA 9775 §§ 4(a),(b),(c) and RA 10175 § 4(c)(2) proven beyond
reasonable doubt: victim’s age, accused’s inducement, production, distribution via
computer.
Search warrant met Rule 126 requirements—probable cause, judge’s personal
examination of witnesses, specific description, lawful execution and proper return;
seized items admissible.
Penalty and Damages
Sentence of reclusion perpetua and fine of ₱2,000,000 upheld.
Civil indemnity increased to ₱100,000; moral damages increased to ₱100,000;
exemplary damages of ₱100,000; all with 6% interest from finality.
Ratio:
Repeal Doctrine
Absolute repeal of penal statute generally extinguishes offenses but simultaneous
reenactment preserves offences and pending prosecutions (United States v. Cuna;
Benedicto v. CA).
Credibility of Minor Victim
Trial court’s evaluation of minor’s testimony and demeanor given great deference;
uncorroborated denial lacks weight against consistent, detailed account.
Search Warrant Validity
Valid warrant requires judge‐determined probable cause after personal interview,
written oath, specific place and item description, and lawful, orderly execution;
requisites duly satisfied.
Doctrine:
Repeal and Reenactment Principle
A repealing statute that reenacts the penal provisions of the old law neutralizes the
repeal, preserving criminal liability and unaffected pending cases.
Search Warrant Essentials
Under Rule 126, Sec. 4: warrant must be based on probable cause, personally
determined by judge, with written sworn statements, and must particularly
describe the place and items to be seized.
Appellate Deference on Credibility
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Appellate courts will not disturb trial court’s determinations on witness credibility
and factual findings absent misapprehension of material evidence or weighty
overlooked circumstances.
Note: AI summaries may not capture all details. Please refer to full text for complete accuracy.
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