Title
Acharon vs. People
Case
G.R. No. 224946
Decision Date
Nov 9, 2021
Christian Acharon acquitted of VAWC charges; SC ruled failure to provide financial support due to hardships, not willful denial, insufficient for conviction under Section 5(i) of R.A. 9262.

Case Digest (G.R. No. 224946)

Facts:

Christian Pantonial Acharon v. People of the Philippines, G.R. No. 224946, November 09, 2021, the Supreme Court En Banc, Caguioa, J., writing for the Court. An Information charged petitioner Christian Pantonial Acharon with violating Section 5(i) of R.A. 9262 for having “willfully, unlawfully and feloniously cause[d] mental or emotional anguish, public ridicule or humiliation to his wife AAA, by denying financial support.” Christian pleaded not guilty and trial proceeded before Branch 270, Regional Trial Court (RTC) of Valenzuela City in Crim. Case No. 34‑V‑13.

At trial the private complainant AAA testified that after their September 30, 2011 civil wedding Christian left for work in Brunei and thereafter sent money irregularly, having remitted about Php71,500 of an Php85,000 placement‑loan balance; she testified that his failure to fully pay caused her embarrassment and anguish and that he maintained a paramour in Brunei. Christian denied willful denial of support, testified he had sent money and stopped only after his rented apartment burned and he suffered a vehicular accident in Brunei, and explained he had paid about Php71,000 toward the loan.

The RTC, in a Decision dated August 26, 2014, convicted Christian under Section 5(i) of R.A. 9262, sentenced him to an indeterminate term (prision correccional to prision mayor) and fined him Php100,000, and required mandatory psychological counseling. Christian appealed to the Court of Appeals (CA), which in a Decision dated February 17, 2016 and a Resolution dated May 31, 2016 affirmed the RTC, holding that refusal to give financial support co...(Subscriber-Only)

Issues:

  • Whether the Court of Appeals erred in sustaining Christian’s conviction under Section 5(i) of R.A. 9262 for “denial of financial support.”
  • Whether evidence that Christian failed to keep communication lines open and maintained a paramour in Brunei could support his conviction when the Information only alleged den...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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