Case Digest (G.R. No. 252087)
Facts:
XXX v. People of the Philippines, G.R. No. 252087, February 10, 2021, Supreme Court First Division, Carandang, J., writing for the Court.
The petitioner, XXX, was charged by Information dated October 12, 2016 with violation of Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004) for allegedly depriving his minor child, CCC, of financial support and thereby causing mental and emotional anguish to his wife, AAA. The case was docketed as Criminal Case No. 16554 before the Regional Trial Court (RTC) of Balanga City, Branch 93.
At trial the prosecution presented AAA and her sister, BBB. AAA testified that she and petitioner had lived together since 1997, that CCC was born in 2000, and that petitioner stopped coming home and providing regular support in about 2005. AAA stated petitioner gave between P1,000–P2,000 per month prior to leaving, agreed at barangay conciliation to give P4,000 but did not comply, and thereafter she relied on BBB’s financial support. BBB corroborated that she supported AAA and CCC financially after petitioner disappeared and that AAA suffered shame and distress over the situation.
Petitioner testified that he left AAA in 2005 because of her alleged violent and harassing conduct, that he made offers to provide support (P1,000–P2,000 monthly and to pay for education if CCC attended public school), and that AAA rejected his offers and pursued complaints against him. He admitted providing some monies on occasion. Petitioner also presented testimony of barangay witnesses and a licensed psychologist, Jesselyn Mortejo, who evaluated him in 2017 and concluded he suffered from Post-Traumatic Stress Disorder (PTSD) with pronounced avoidance and paranoid ideations that substantially impaired his capacity to seek or sustain outside work, though he was not insane and retained moral reasoning.
The RTC gave full weight to the prosecution evidence, found all elements of Section 5(i) proven (relying on Dinamling v. People for the elements), convicted petitioner on March 19, 2018 and sentenced him to an indeterminate term. Petitioner appealed to the Court of Appeals (CA), which on November 5, 2019...(Pro-only)
Issues:
- Did the Court of Appeals commit reversible error in affirming the RTC's conviction of petitioner for violating Section 5(i) of R.A. 9...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)