Case Digest (G.R. No. 239313) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Cesar M. Calingasan, petitioner Cesar M. Calingasan and private complainant AAA married on November 27, 1995 in Manila and had a son, BBB, on January 22, 1997. Sometime in October 1998, Calingasan left the conjugal home promising remittances; thereafter, private complainant lost contact when he ceased seafaring employment and allegedly migrated to Canada. From 1998 to 2010, private complainant financed household expenses, educational fees (approximately ₱500,000), utilities, and rent for herself and BBB. In 2010 she fell ill and contacted Calingasan via email for ₱160,000 per year and a ₱6,000 monthly allowance. Calingasan claimed bankruptcy of his Canadian business and inability to pay. At trial before the RTC, the prosecution presented receipts for expenses and private complainant’s testimony. The defense introduced Calingasan’s testimony and his brother Danilo’s, detailing remittances sent until 2005, Calingasan’s 2009 imprisonment in British C Case Digest (G.R. No. 239313) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and relationship
- Cesar M. Calingasan (petitioner) and AAA (private complainant) married on November 27, 1995 in Manila; they have a son, BBB, born January 22, 1997.
- Their marriage was marked by frequent quarrels witnessed by their son.
- Separation and support history
- In October 1998, petitioner left the conjugal home, promising financial support as a seaman earning US$939.00 per month, but allegedly sent no funds thereafter.
- Private complainant worked as a seafarer and solely supported BBB, paying rent, utilities, groceries, and approximately ₱500,000.00 in elementary and high-school fees; by the time of trial, BBB was a college student.
- Prosecution’s evidence
- In 2010, private complainant fell ill, could no longer work, depleted her savings, and relied on relatives; she then emailed petitioner for ₱160,000.00 per year plus ₱6,000.00 monthly allowance.
- Petitioner allegedly claimed bankruptcy in Canada and refused further support. Receipts for tuition, dental expenses, utilities, and rent were presented.
- Defense’s evidence
- Petitioner testified he sent remittances and items from 1998 to 2005; in 2009 he was convicted of sexual assault in British Columbia, jailed until 2010, and upon release could not find work.
- His brother, Danilo, offered private complainant post-dated checks of ₱7,500.00 per month or lump-sum payment in exchange for withdrawal of the complaint; private complainant demanded ₱1,400,000.00 or ₱300,000.00 for a condominium, which Danilo could not provide.
Issues:
- Whether the prosecution proved beyond reasonable doubt all elements of Section 5(i) of R.A. 9262, specifically:
- That petitioner willfully or consciously denied financial support legally due private complainant and their child.
- That such denial was for the purpose of inflicting mental or emotional anguish, public ridicule, or humiliation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)