Case Digest (G.R. No. 156013) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Roberto P. de Guzman v. Hernando B. Perez, G.R. No. 156013, decided on July 25, 2006 under the 1987 Constitution, petitioner Roberto P. de Guzman and private respondent Shirley F. Aberde became romantically involved while both were law students at the University of Santo Tomas. Their relationship ended without marriage, and on October 2, 1987, Aberde gave birth to their son, Robby Aberde de Guzman. In 1991 petitioner wed another woman and fathered two more children. He remitted financial support for Robby only on two occasions—once in 1992 and again in 1993—and in 1994 sent ₱7,000 for hospitalization expenses when the child fell seriously ill. Thereafter, Aberde secured employment in Taiwan (1994–1996) to fund Robby’s schooling. By 2000, her resources were nearly depleted and the boy faced high-school enrollment. On February 21, 2000 Aberde formally demanded educational support, but petitioner made no further contributions. Consequently, on June 15, 2000 Aberde filed a crimin Case Digest (G.R. No. 156013) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Relationship and birth of child
- Petitioner Roberto P. de Guzman and private respondent Shirley F. Aberde became sweethearts while studying law at the University of Santo Tomas.
- Their child, Robby Aberde de Guzman, was born on October 2, 1987; the parents never married.
- Petitioner’s subsequent family life and minimal support
- In 1991 petitioner married another woman and fathered two more children.
- He sent money for Robby’s schooling only twice (1992 and 1993) and gave ₱7,000 in 1994 for medical expenses; no further support was provided.
- Private respondent’s efforts to provide for Robby
- From 1994 to 1996 she worked as a factory worker in Taiwan to support her son and herself.
- She relied on her savings and relatives’ charity to enroll Robby in high school in Lipa City.
- Demand for support and criminal complaint
- On February 21, 2000, private respondent formally demanded educational support for Robby; petitioner ignored the demand.
- On June 15, 2000, she filed a criminal complaint for abandonment and neglect of a child under Article 59(2) and (4) of PD 603 (I.S. No. 2000-2111).
- Proceedings before the City Prosecutor and Secretary of Justice
- Petitioner filed a counter-affidavit claiming financial incapacity and disputing ownership of assets; private respondent submitted a General Information Sheet showing ₱750,000 in paid-up shares.
- On August 15, 2000, the City Prosecutor dismissed the abandonment charge but found probable cause for neglect under PD 603 art. 59(4) in relation to RA 7610 § 10(a) and filed information.
- Petitioner sought review with the Justice Secretary; on January 3 and September 24, 2002, the Secretary dismissed the petition and denied reconsideration.
Issues:
- Whether petitioner’s failure to provide his child the education his station in life and financial condition permit constitutes neglect of a child under Article 59(4) of PD 603.
- Whether the Secretary of Justice acted with grave abuse of discretion in affirming the City Prosecutor’s resolution finding probable cause.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)