Case Digest (G.R. No. 255877)
Facts:
In XXX v. People of the Philippines, the petitioner XXX was charged by an Amended Information dated December 14, 2016, with violation of Section 5(i) of R.A. No. 9262 for committing economic abuse and psychological violence against his wife, AAA, in Quezon City. According to the prosecution, the couple married on October 14, 2002, and lived together until 2004 when XXX left for work as a seafarer. He initially remitted part of his salary to AAA but ceased remittances a few months later and never communicated with her for the next thirteen years. AAA claimed the abrupt stoppage caused her extreme mental anguish and financial ruin of her sari-sari store, forcing her to work as a freelance massage therapist. In 2013, CCC, AAA’s sister, saw XXX back in the Philippines but he still did not contact his wife. XXX testified that he was compelled to marry AAA, resumed work ashore in 2007, and halted support only to cover his parents’ cancer treatment, without willful intent to harm AAA. ...Case Digest (G.R. No. 255877)
Facts:
- Criminal Information and Proceedings
- On December 14, 2016, an Amended Information was filed in RTC Quezon City, Branch 94, docketed as Criminal Case No. R-QZN-16-13802-CR, charging XXX with violation of Section 5(i) of R.A. No. 9262 for psychological violence and economic abuse against his wife, AAA, by abandoning her and denying financial support from 2004 to present.
- XXX pleaded not guilty on April 7, 2017. Trial on the merits followed.
- Version of the Prosecution
- AAA testified that they married on October 14, 2002, lived together until XXX left in 2004 to work as a seafarer, initially remitting support but ceasing after a few months; last communication was in 2004 when he told her to live in Antique, which she refused. For 13 years he neither communicated nor supported her, causing her mental anguish; her sari-sari store failed and she became a freelance massage therapist.
- CCC, AAA’s sister, saw XXX in 2013 back in the country near a car wash station, but he made no contact with AAA.
- Version of the Defense
- XXX testified that he was coerced into marrying AAA on October 14, 2002; from 2004 to 2007 he worked as a seafarer and initially sent remittances but asked his employer in 2004 to stop due to his parents’ serious illnesses (liver and lung cancer), which required high medical expenses.
- He did not inform AAA of the stoppage because they had become estranged from frequent fights and no longer communicated; upon returning in 2007, he worked as a maritime instructor but still did not contact or support AAA because the marriage was forced.
- RTC and CA Rulings
- RTC Decision (November 24, 2017): Convicted XXX of violating Section 5(i) of R.A. No. 9262; imposed indeterminate sentence of 2 years, 4 months, 1 day to 6 years, 1 day imprisonment, fine of ₱100,000, mandatory psychological counseling, and costs. Reconsideration denied on January 22, 2018.
- CA Decision (September 12, 2019) and Resolution (February 11, 2021): Denied XXX’s appeal; affirmed RTC decision, holding that his unilateral cessation of support and communication caused AAA’s psychological suffering, and that marital obligation to support is mandatory notwithstanding his coercion claim.
- Petition for Review on Certiorari
- XXX’s petition to the Supreme Court argued: lack of prior demand for support; absence of elements of economic abuse; no conjugal home; mutuality of support under Family Code Articles 68 and 100; and alleged vagueness of Section 5(i) of R.A. 9262.
- The State, via OSG, opposed dismissal, asserting elements were proven, demand unnecessary, and that XXX’s abandonment and non-support for 13 years satisfied economic abuse under R.A. 9262.
Issues:
- Whether XXX is guilty beyond reasonable doubt of violating Section 5(i) of R.A. No. 9262 by willfully denying financial support to AAA to cause her mental or emotional anguish.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)