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CHRISTIAN CADAJAS Y CABIAS, PETITIONER, VS.

PEOPLE OF THE
PHILIPPINES,
RESPONDENT.
CHRISTIAN CADAJAS Y CABIAS, PETITIONER, VS. PEOPLE OF THE
PHILIPPINES,
RESPONDENT.
CHRISTIAN CADAJAS Y CABIAS, PETITIONER, VS. PEOPLE OF THE
PHILIPPINES,
RESPONDENT.

CHRISTIAN CADAJAS Y CABIAS, PETITIONER, VS. PEOPLE OF THE


PHILIPPINES, RESPONDENT.

[ G.R. No. 247348. November 16, 2021]

Ponente: J.Y Lopez, J.

FACTS:

Petitioner is a 24-year-old male, and the victim is a 14-year-old


female. They met in a canteen where the petitioner works.
AAA, the victim, stalked the petitioner, and the former sent
him a friend request in Facebook which the latter accepted.

In an unfortunate instance, the mother of AAA happened to


access the messenger of the latter. AAA logged on his account
to her mother’s phone, and the former forgot to log out. The
mother screenshot the messenger thread.
The mother filed two (2) criminal cases against the petitioner.
The petitioner was acquitted with the violation of Section 10
(a) of RA 7610, but he was found guilty beyond reasonable
doubt for violating Section 4 (c) of RA 10175 (Child
Pornography).
CA affirmed the decision of the RTC. Hence, the petition
lodged in the Supreme Court.
Petitioner is a 24-year-old male, and the victim is a 14-year-old
female. They met in a canteen where the petitioner works.
AAA, the victim, stalked the petitioner, and the former sent
him a friend request in Facebook which the latter accepted.

In an unfortunate instance, the mother of AAA happened to


access the messenger of the latter. AAA logged on his account
to her mother’s phone, and the former forgot to log out. The
mother screenshot the messenger thread.
The mother filed two (2) criminal cases against the petitioner.
The petitioner was acquitted with the violation of Section 10
(a) of RA 7610, but he was found guilty beyond reasonable
doubt for violating Section 4 (c) of RA 10175 (Child
Pornography).
CA affirmed the decision of the RTC. Hence, the petition
lodged in the Supreme Court.

Petitioner is a 24-year-old male, and the victim is a 14-year-old female. They met
in a canteen where the petitioner works. AAA, the victim, stalked the petitioner,
and the former sent him a friend request in Facebook which the latter accepted.

In an unfortunate instance, the mother of AAA happened to access the messenger


of the latter. AAA logged on his account to her mother’s phone, and the former
forgot to log out. The mother screenshot the messenger thread.

The mother filed two (2) criminal cases against the petitioner. The petitioner was
acquitted with the violation of Section 10 (a) of RA 7610, but he was found guilty
beyond reasonable doubt for violating Section 4 (c) of RA 10175 (Child
Pornography).

CA affirmed the decision of the RTC. Hence, the petition lodged in the Supreme
Court.

ISSUE:

Whether or not the lower courts erred when it accepted evidence obtained in
violation of his right to privacy.
Ruling:

Upon a careful review of the records of this case, the Court finds the petition to be
without merit.

On petitioner's right to privacy

One of the arguments raised by petitioner before this Court concerns the
admissibility of the evidence presented by the prosecution, which was taken from
his Facebook messenger account. He claims that the photos presented in evidence
during the trial of the case were taken from his Facebook messenger account.
According to him, this amounted to a violation of his right to privacy, and
therefore, any evidence obtained in violation thereof amounts to a fruit of the
poisonous tree.

We disagree

The right to privacy is defined as "the right to be free from unwarranted


exploitation of one's person or from intrusion into one's private activities in such a
way as to cause humiliation to a person's ordinary sensibilities." It is the right of an
individual "to be free from unwarranted publicity, or to live without unwarranted
interference by the public in matters in which the public is not necessarily
concerned." Simply put, the right to privacy is "the right to be let alone."[29] In his
Separate Concurring Opinion, Associate Justice Marvic Mario Victor F. Leonen
expounded on the concept of privacy, as it has developed throughout the digital
age, thus:

Chief Justice Puno sparked judicial interest in the right to privacy. In his speech
that I cited in my separate opinion in Versoza v. People,.

Under the 1987 Constitution, the right to privacy is expressly recognized under
Article III, Sec. 3 thereof, which reads:
SECTION 3. (1) The privacy of communication and correspondence shall be
inviolable except upon lawful order of the court, or when public safety or order
requires otherwise as prescribed by law.

(2) Any evidence obtained in violation of this or the preceding section shall be
inadmissible for any purpose in any proceeding.
While the above provision highlights the importance of the right to privacy and its
consequent effect on the rules on admissibility of evidence, one must not lose sight
of the fact that the Bill of Rights was intended to protect private individuals against
government intrusions. Hence, its provisions are not applicable between and
amongst private individuals. As explained in People v. Marti:[

WHEREFORE, the petition is DENIED. Consequently, The Decision dated


September 27, 2018 and Resolution dated May 9, 2019 both rendered by the Court
of Appeals in CA-G.R. CR No. 40298
are AFFIRMED with MODIFICATION. Petitioner Christian Cadajas y Cabias is
guilty beyond reasonable doubt of the crime of child pornography under Section
4(c)(2) of R.A. No. 10175, in relation to Sections 4(a) and 3(b) and (c)(5) of R.A.
No. 9775. He is sentenced to reclusion perpetua, with all its accessory penalties
and to pay a fine in the amount of One Million Pesos (P1,000,000.00).

Legal principle: SECTION 3. (1) The privacy of communication and


correspondence shall be inviolable except upon lawful order of the court, or when
public safety or order requires otherwise as prescribed by law.

Court Application: One must not lose sight of the fact that the Bill of Rights was
intended to protect private individuals against government intrusions. Hence, its
provisions are not applicable between and amongst private individuals. As
explained in People v. Marti:

Ratio decidendi: That the Bill of Rights section 3 was intended to protect
individuals against government intrusions, its provisions are not applicable
between amongst individuals as explained in People v Marti.

SOURCE/RESEARCH TOOL: STUDOCU.COM

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