State’s obligation to defend the rights of children from all forms of abuse, reinforced in Sps. Dorao v. Sps. David case

The Supreme Court ruled in the case of Sps. Melchor & Yolanda Dorao v. Sps. Reynaldo & Nanet David, G.R. No. 235737, affirming the State’s commitment to use a child right-based parenting, caring, and teaching style and to place the child’s best interests in all actions concerning children, citing the State’s policies and obligation pursuant to the United Nations Convention on the Rights of the Child to defend the rights of children from all forms of abuse.

David Spouses filed a Petition for Review on Certiorari, seeking to protect their minor daughter’s right to a peaceful life and privacy, praying that the Dorao Spouses be held liable for damages for undertaking the wrong approach of, and in assuming the responsibility of, disciplining their daughter.

According to the facts of the case, the Dorao Spouses were intent in staving off their son and other students from getting closer with the David Spouses’ minor-daughter; they also made untoward pronouncements at the latter and called her “a flirt (“malanding babae”), a woman with loose morals (“puta”), and allegedly sexually aggressive (“makati ang laman”),’ which were loud enough to be heard by the minor’s peers, teachers, and parents.

Such comments, according to the Supreme Court, “caused the young and impressionable child to feel harassed, intimidated, and exposed to repeated public ridicule and humiliation, adversely affecting her emotional and psychological wellbeing.” Thus, the lower court ruled against the Dorao Spouses who “undoubtedly exposed David Spouses’’ daughter to public ridicule, causing the latter mental anguish, besmirched reputation, wounded feelings, and social humiliation.”

In sustaining the lower court’s Decision, the Supreme Court Second Division, through Senior Associate Justice Marvic M.V.F. Leonen, found the Dorao Spouses jointly and severally liable for damages for harassing, intimidating, and spreading false and malicious rumors about David Spouses and the latter’s daughter. The Second Division found petitioners’ actions to be violative of respondents’ rights under Article 26 of the Civil Code and to be contrary to morals, good customs, or public policy.