Case Digest (G.R. No. 232678)
Facts:
In Esteban Donato Reyes v. People of the Philippines (G.R. No. 232678, July 3, 2019), petitioner Esteban Donato Reyes was charged before the Regional Trial Court (RTC), Branch 89, Quezon City, under an Information dated June 5, 2006, alleging violation of Section 5(e), paragraph 2 of Republic Act No. 9262 (the Anti-Violence Against Women and Their Children Act of 2004). The complainant (“AAA”), his legal wife since May 15, 1969, claimed that Reyes abruptly ceased monthly financial support of ₱10,000–₱20,000 from July 2005, causing her emotional distress and deteriorating health. The RTC issued a Temporary Protection Order on March 12, 2007 directing Reyes to resume support at ₱20,000 monthly, and a Hold Departure Order on August 30, 2007. Reyes moved to quash the Information, insisting that “abandoning without financial support” is not an offense under RA 9262, but the RTC denied the motion, amended the charge to Section 5(i) (psychological violence), and proceeded to trial. TheCase Digest (G.R. No. 232678)
Facts:
- Background
- Reyes and AAA were married on May 15, 1969, and had four children (three living).
- Reyes worked as a Philippine Air Force pilot and later a commercial pilot; AAA was dependent on his monthly support of ₱10,000–₱20,000.
- Procedural History
- June 5, 2006 – Information filed for violation of R.A. 9262 § 5(e)(2), later amended to § 5(i) before arraignment.
- March 12, 2007 – RTC issued Temporary Protection Order directing Reyes to resume ₱20,000 monthly support.
- August 30, 2007 – Hold Departure Order issued against Reyes.
- October 28, 2008 – TPO made permanent.
- June 11, 2009 – Reyes moved to quash Information; denied.
- March 3, 2016 – RTC convicted Reyes of VAWC § 5(i), sentenced him to indeterminate penalty of 3 years prision correccional to 8 years 1 day prision mayor.
- June 23, 2017 – CA affirmed conviction.
- Trial Evidence
- Prosecution
- AAA testified support ceased in July 2005; she suffered hypertension, diabetes, osteoarthritis; mental and emotional anguish ensued.
- Daughter and physician corroborated her deteriorating health and distress caused by loss of support.
- Defense
- Reyes claimed no valid marriage (signature forged), asserted common-law relationship.
- Admitted prior support, ceased July 2006 due to AAA’s bigamy complaint; detailed other support (medical, educational).
Issues:
- Whether the Court of Appeals erred in affirming the order compelling Reyes to resume monthly financial support under the TPO.
- Whether the Court of Appeals erred in upholding Reyes’s conviction for violation of R.A. 9262 § 5(i) and his imposed penalty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)