Case Digest (G.R. No. 252087) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People v. XXX, G.R. No. 252087, decided on February 10, 2021 under the 1987 Constitution, the petitioner was charged by Information dated October 12, 2016 with violating Section 5(i) of Republic Act No. 9262 for allegedly willfully denying financial support to his minor daughter, CCC, thus causing mental and emotional anguish to his wife, AAA. The Regional Trial Court of Balanga City, Branch 93, after a full trial, found that from 2005 onward the petitioner ceased regular remittances—initially only P1,000–P2,000 monthly—and defaulted on a barangay-mandated P4,000 support agreement, forcing AAA’s sister, BBB, to assume financial responsibility. AAA testified to her economic dependence and emotional distress, while BBB corroborated her sister’s suffering and outlay of US$1,000 per month for CCC’s upkeep. Petitioner admitted he worked as a mechanic until 2010, offered support which AAA refused because she demanded private schooling for CCC, and claimed he was incapacitated by Po... Case Digest (G.R. No. 252087) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- On October 12, 2016, an Information was filed charging XXX (petitioner) with violation of Section 5(i) of R.A. 9262 for willfully depriving his minor daughter, CCC, of financial support.
- Following a not-guilty plea, the Regional Trial Court (RTC) of Balanga City, Branch 93, rendered judgment on March 19, 2018, finding petitioner guilty and sentencing him to 6 months and 1 day of prisión correccional as minimum to 8 years and 1 day of prisión mayor as maximum.
- The petitioner’s appeal to the Court of Appeals (CA) was denied in a decision dated November 5, 2019, modified only to impose a fine of ₱100,000 and mandatory counseling. Reconsideration was denied on January 23, 2020.
- Prosecution Evidence
- AAA (wife) and BBB (AAA’s sister) testified that AAA and petitioner lived together from 1997, married in 2001, and had CCC in 2000. AAA had no income and depended on petitioner’s monthly contributions of ₱1,000–₱2,000 until 2004.
- In 2005, petitioner ceased coming home and stopped support. Barangay conciliation produced a promise of ₱4,000 per month, but petitioner only paid ₱1,000 once. AAA then relied on BBB’s remittances (US$1,000/month) for housing, schooling, and medical expenses until filing the criminal complaint in 2016.
- Defense Evidence
- Petitioner attributed his departure in 2005 to AAA’s alleged violence (a dustpan attack) and harassment. He claimed to have offered ₱1,000–₱2,000 monthly plus public-school tuition, which AAA rejected in favor of private schooling.
- He worked as a mechanic until 2010, then suffered from hypertensive cardiovascular disease and Post-Traumatic Stress Disorder (PTSD) resulting in paranoid ideation and avoidance symptoms. Witnesses (barangay official, neighbor) confirmed his capacity for limited home activities but testified on his psychological incapacity to work outside. A psychologist’s evaluation (Mortejo) diagnosed chronic PTSD, low coping mechanisms, and significant impairment in performing normal work functions without therapy.
Issues:
- Whether the Court of Appeals erred in affirming the RTC’s conviction of petitioner for violation of Section 5(i) of R.A. 9262 when:
- There was no proof that petitioner willfully denied financial support with intent to cause psychological violence; and
- Petitioner’s PTSD and related mental debilitation incapacitated him from fulfilling his support obligations.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)