Parental authority vis-à-vis child’s best interest

"The best interest of a child cannot justify forms of cruel or degrading punishment which conflict with a child's human dignity, including punishment which belittles, humiliates, denigrates, scapegoats, threatens, scares or ridicules a child. A person who debases, degrades, or demeans the child's intrinsic worth and dignity as a human being can be held liable for damages pursuant to Articles 21 and 26 of the Civil Code."

In Sps. Melchor and Yolanda Dorao vs. Sps. BBB and CCC, by themselves and as natural guardians of their Minor daughter AAA (G.R. No. 235737, 26 April 2023), the Supreme Court found Spouses Dorao liable for moral and exemplary damages for spreading malicious rumors about minor AAA and exposing the latter to public ridicule.

AAA was the girlfriend of Spouses Dorao's son, Paul. Spouses Dorao disapproved of AAA and Paul's relationship. On multiple occasions, Spouses Dorao would publicly call AAA a flirt and a woman of loose morals. Worse, Spouses Dorao started spreading derogatory rumors about AAA among other students, parents, and guardians. For this reason, AAA fell into a depression, attempted suicide, and abruptly dropped out of school.

Seeking to protect their child, AAA's parents went to court claiming damages against Spouses Dorao for their alleged violation of AAA's and their family's right to privacy and peaceful life. In defense, Spouses Dorao argued that their actions were done pursuant to a concomitant parental duty to provide a moral fiber to Paul.

The Supreme Court ruled that Spouses Dorao could not justify their abusive acts under the pretense of exercising parental authority. First, their actions did not constitute the kind of parental authority contemplated in the Constitution. Second, they were not AAA's parents or legal guardians. Thus, regardless of their intentions, they exercised no parental authority over AAA. Third, Spouses Dorao's resort to harsh and degrading methods of discipline could not be countenanced as these were contrary to public policy, in any case.

The Supreme Court also went on to remind that, indeed, no less than the Constitution recognizes the rights of parents in rearing their children.
While neither the Constitution nor the Convention prescribed in detail how parents must relate to, or guide their children, the Convention provides a framework that guides relationships within the family and between third persons and children.

The Convention emphasizes the use of child-right-based parenting, caring, and teaching style. In all actions concerning children, the child's best interests shall be the primary consideration. A child must be respected as an active person in their own right with their own concerns, interests, and points of view, and should not be treated as a parent's possession or merely as an "object of concern."

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