If disciplining children results in harming their dignity, it is considered child abuse, the Supreme Court said in a decision last year but promulgated only on 9 January.

In a decision penned by Associate Justice Jhosep Y. Lopez dated 22 July 2024, the SC’s Second Division upheld the conviction of a father for child abuse after he had subjected his 12-year-old daughter and 10-year-old son to violent and excessive discipline.

Records showed that the father from 2017 to 2018 beat his children, kicking his daughter, pulling her hair, striking her with a wooden rod with a nail, hitting them with a dustpan, and cursing at them repeatedly.

He claimed these actions were meant to discipline his children for misbehavior, such as failing to eat lunch and losing money from their coin banks.

The father was found guilty by a Regional Trial Court and the Court of Appeals for violating Republic Act 7610, or the Special Protection of Children Against Abuse, Exploitation and Discrimination Act.

Under Section 3(b) of RA 7610, any act that debases, degrades, or demeans a child’s dignity is considered child abuse.

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.

While parents have the right to discipline their children, such measures must not be violent, excessive, or disproportionate to their misbehavior, the SC said.

It noted that without this specific intent, the offender cannot be held liable for child abuse but can be charged with other crimes under the Revised Penal Code.

The father was sentenced to four to six years in prison and fined P45,000. He was also ordered to pay his children P180,000 in damages.

The court reiterated that disciplining children, if it results in physical injuries, does not automatically amount to child abuse.

For such acts to be considered abuse, there must be a clear intent to harm a child’s dignity, it explained.