Case Digest (A.M. No. P-09-2705, P-09-2737) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In BBB v. AAA (G.R. No. 193225, February 9, 2015), petitioner BBB and respondent AAA first met in 1991 and began a serious relationship in 1996. AAA, then a medical student, had a son CCC from a prior relationship and later bore two children with BBB, namely DDD (b. December 11, 1997) and EEE (b. October 19, 2000). They married on October 10, 2002, and amended their children’s birth certificates to legitimize all three. Their marriage deteriorated amid accusations of marital infidelity, psychological and economic abuse, and stalking. AAA sought relief under the Anti-Violence Against Women and Their Children Act of 2004 (R.A. No. 9262), and the Regional Trial Court (RTC) of Pasig City issued in August 2007 a Permanent Protection Order (PPO) prohibiting BBB from harassing, verbally abusing, or exposing the children to an illicit environment; granting AAA sole custody; limiting BBB to monthly supervised visits; and ordering BBB to pay support, post a bond, and shoulder attorney’s f Case Digest (A.M. No. P-09-2705, P-09-2737) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Relationship and Family Background
- BBB and AAA met in 1991, began dating seriously in 1996. AAA had a son, CCC, from a prior relationship; with BBB she bore DDD (1997) and EEE (2000). They married on October 10, 2002, and legitimated all three children.
- Marital discord arose: BBB alleged AAA’s jealousy over his female colleagues, AAA charged BBB with habitual womanizing and cited public humiliation by his mistress FFF. AAA left the conjugal home with the children (leaving CCC temporarily with a friend), then returned with DDD and EEE; BBB also left to avoid conflict.
- Allegations of Abuse and Trial Court Proceedings
- AAA alleged economic abuse (BBB’s failure to pay rent, insufficient support, compelled to borrow) and psychological abuse (stalking through a friend, GGG).
- AAA secured a Temporary Protection Order (TPO) and then, on August 14, 2007, a Permanent Protection Order (PPO) under RA 9262. The PPO, among others, prohibited stalking or verbal abuse, granted AAA sole custody, limited BBB to one supervised visit monthly, ordered support of ₱62,918.97/month, imposed a ₱300,000 peace bond, and awarded AAA ₱100,000 attorney’s fees.
- Appellate History and Supreme Court Petition
- BBB appealed to the Court of Appeals (CA), challenging issuance of the PPO, custody award, bond amount, attorney’s fees, and evidence admission. On November 6, 2009, the CA affirmed the PPO with modification: it remanded the custody issue to the RTC but upheld the other orders. A motion for reconsideration was denied on August 3, 2010.
- BBB filed a Rule 45 petition before the Supreme Court raising five issues, later submitted a Memorandum of Agreement (MOA) on custody and support which AAA’s counsel contested as signed under duress.
Issues:
- Whether the CA erred in affirming the RTC’s issuance of the PPO.
- Whether the CA erred in affirming the award of attorney’s fees and litigation costs to AAA.
- Whether the CA erred in affirming the order requiring BBB to post a ₱300,000 peace bond.
- Whether the CA and RTC correctly admitted unauthenticated text messages as evidence.
- Whether the support award should be deleted because DDD and EEE have been in BBB’s actual custody since AAA went to work abroad.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)