Case Digest (G.R. No. 104234) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In XXX v. People of the Philippines (G.R. No. 221370, June 28, 2021), petitioner XXX and complainant AAA, high school acquaintances, married on March 8, 2005 in xxxxxxxxxxx City after AAA’s pregnancy. Their son, BBB, was born on August 2, 2005 and later diagnosed with Congenital Torch Syndrome, resulting in hearing impairment and delayed development. AAA initially shared hospital expenses with her mother and XXX, but XXX refused subsequent requests for financial support for BBB’s hearing aid (costing approximately ₱35,000), medical procedures, special schooling, and potential cochlear implants. Between 2005 and 2010, XXX purportedly provided minimal support only five times; substantial monthly contributions (₱4,000) began only after the Office of the City Prosecutor recommended charges. AAA filed a complaint for violation of Section 5(e)(2) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act). The Regional Trial Court of xxxxxxxxxxx City, Branch 199 (Cri... Case Digest (G.R. No. 104234) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- An information was filed against petitioner XXX for violation of Section 5(e)(2) of RA 9262 (Anti-Violence Against Women and Their Children Act) for willfully depriving his wife AAA and their son BBB of financial support.
- AAA and XXX began dating in college; AAA became pregnant, leading to their marriage on March 8, 2005. They lived with XXX’s family, but after domestic quarrels and alleged mistreatment, AAA left after two months.
- Child’s condition and expenses
- AAA gave birth to BBB on August 2, 2005; the child was diagnosed with Congenital TORCH Syndrome, causing developmental delay and profound hearing loss.
- AAA spent about ₱35,000 on a hearing aid and later shouldered ₱20,000 annual tuition for a special school. She sought financial help from XXX, who repeatedly refused, claiming insufficient means.
- Corroborative testimonies
- Danielle Joanne Raymundo, a speech and language pathologist, confirmed BBB’s profound hearing loss, recommended cochlear implants (≈₱1,000,000 per ear) plus weekly therapy, and opined that prompt intervention was critical.
- DDD, AAA’s mother, testified that XXX only provided support two to three times before the case was filed and observed AAA’s sole financial burden in raising BBB.
- Petitioner’s defense
- XXX denied deliberate deprivation, claiming AAA abused him physically and emotionally, pressured him to abandon studies, and forced a separation “agreement” (kasunduan).
- He asserted he paid all hospital expenses (~₱25,000), intermittently sent money (₱1,500–2,000 monthly in 2008; receipts for 2010–2013), and only ceased support because AAA allegedly prevented compliance.
- Procedural history
- RTC Branch 199 of xxxxxxxxxxx City (Dec 2, 2013) found XXX guilty beyond reasonable doubt: 6 months + 1 day prision correccional, fine ₱100,000, moral damages ₱10,000, mandatory psychological counseling.
- CA (Nov 3, 2015) affirmed the RTC decision.
- XXX filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, raising purported errors in the fact‐finding and malice requirement.
Issues:
- Did petitioner XXX deliberately deprive AAA and BBB of financial support legally due, in violation of Section 5(e)(2) of RA 9262?
- Are the factual findings on support payments and marital circumstances subject to reopening in a Rule 45 petition?
- Is malice or specific intent an essential element for economic abuse under RA 9262?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)