Case Digest (G.R. No. 170375)
Facts:
In G.R. No. 224946, November 9, 2021, the Supreme Court, En Banc, resolved a petition by Christian Pantonial Acharon (petitioner) against the People of the Philippines (respondent). On January 25, 2012, an Information was filed before the Regional Trial Court (RTC) of Valenzuela City accusing Acharon of willfully causing emotional anguish to his wife, AAA, by denying her financial support in violation of Section 5(i) of Republic Act No. 9262 (VAWC Law). The couple had married on September 30, 2011, and six days later petitioner departed for Brunei to work as a delivery rider under an P85,000 placement fee loan. He allegedly pledged to remit ₱9,633 monthly but sent only ₱71,500, leaving ₱13,500 unpaid. The RTC admitted evidence that petitioner maintained a paramour in Brunei, leading to his conviction on August 26, 2014, sentencing him to 2 years, 4 months, 1 day to 6 years, 1 day of imprisonment and a ₱100,000 fine. The Court of Appeals (CA), in CA-G.R. CR No. 36913, affirmed boCase Digest (G.R. No. 170375)
Facts:
- Information and proceedings
- An Information dated January 25, 2012 charged petitioner Christian Pantonial Acharon with violation of Section 5(i) of Republic Act No. 9262 (RA 9262) for “willfully, unlawfully and feloniously cause[ing] mental or emotional anguish, public ridicule or humiliation to his wife AAA, by denying financial support.”
- At trial before Branch 270, RTC Valenzuela City, petitioner pleaded not guilty. On August 26, 2014, he was convicted: imprisonment of two (2) years, four (4) months and one day to six (6) years and one day, fine of ₱100,000, and mandatory psychological counseling.
- Prosecution’s version
- AAA testified they married September 30, 2011; petitioner left October 6, 2011 for work in Brunei after borrowing ₱85,000 (3% monthly interest); they agreed he would remit ₱9,633 monthly but he sent only ₱71,500, leaving a ₱13,500 balance. AAA felt embarrassed before their creditor.
- AAA further alleged petitioner had a paramour in Brunei, showed her photos (Exhs. C–C-5), suffered depression, and received a message he no longer cared for her.
- Defense’s version
- Petitioner denied wrongdoing; his initial two-and-a-half-year Brunei stint extended until February 2014 due to apartment fire and a vehicular accident that required ₱1,000 (US$) in medical expenses.
- He remitted ₱71,000; AAA allegedly told him to stop sending further funds; communication was on-and-off until April 2013.
- Court of Appeals Decision
- In CA-G.R. CR No. 36913, the CA (Feb 17, 2016) affirmed the RTC: refusal to give financial support constitutes economic abuse under Section 5(i).
- Petitioner moved for relief under Rule 45; case elevated to the Supreme Court (G.R. No. 224946).
Issues:
- Whether the CA erred in finding petitioner guilty of Section 5(i) RA 9262 on the grounds that he:
- Denied financial support to AAA; and
- Failed to keep open lines of communication with her.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)