Case Digest (G.R. No. 256611) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In XXX256611 v. People, decided October 12, 2022 under G.R. No. 256611, petitioner XXX256611, a retired Philippine National Police officer, was charged before the Regional Trial Court (RTC), Branch 94, Quezon City, by Information dated October 31, 2014 for violation of Section 5(i) of Republic Act No. 9262 (“Anti-Violence Against Women and Their Children Act of 2004”). His common-law wife, AAA256611, testified that they cohabited from 1999 to 2002 and had two children, BBB256611 and CCC256611. She alleged that despite an agreement in August 2008 for a monthly allowance of ₱1,000 for their children, XXX256611 provided inconsistent support until he ceased payments in 2010. After optionally retiring in November 2013, he received substantial retirement benefits and pension but failed to remit any support. In his defense, he claimed he had supported his children until a disabling truck accident in August 2012, which led to hospital bills, loss of a leg and hand function, mortgage and Case Digest (G.R. No. 256611) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents and Charge
- In October 2014, petitioner XXX256611 was charged under Section 5(i) of RA 9262 for causing psychological and emotional anguish to AAA256611 (his live-in partner) and depriving her and their two children of financial support.
- The offense was tried in RTC Branch 94, Quezon City, with XXX256611 pleading “not guilty.”
- Prosecution Evidence
- AAA256611 testified that from 2005 to 2010, XXX256611 intermittently sent money and then ceased support entirely despite a 2008 agreement to pay PHP 1,000 monthly per child.
- In 2014, petitioner received retirement benefits (PHP 761,206.68), leave commutation (PHP 953,685.99), and a monthly pension (PHP 21,144.63) but did not remit any support thereafter.
- AAA256611 presented an unauthenticated letter allegedly penned by their children expressing distress over non-support.
- Defense Evidence
- XXX256611 claimed consistent support through Cebuana Lhuillier remittances and P4,000 monthly for a nanny until August 2012.
- On August 3, 2012, he suffered a vehicular accident resulting in amputation of a leg and impairment of an arm, incurring medical expenses (~PHP 1.4M), mortgaging family property, and securing loans (PHP 700,000).
- Retirement benefits and pension were used to settle debts, medical costs, and personal subsistence; petitioner is also diagnosed with stage III prostate cancer.
- RTC Decision
- On April 20, 2018, the RTC found petitioner guilty of violating Section 5(i) RA 9262, sentencing him to 2 years 4 months 1 day to 6 years 1 day of prision correccional, a PHP 100,000 fine, and mandatory psychological counseling.
- Court of Appeals Decision
- On June 8, 2020, the CA affirmed conviction but modified the crime to Section 5(e)(2) RA 9262 (deprivation of support without psychological violence).
- The CA imposed 6 months arresto mayor to 4 years 2 months prision correccional, a PHP 300,000 fine, and counseling, applying the variance doctrine.
- Petition to the Supreme Court
- Petitioner asserted lack of willful denial given his accident-related incapacity and use of benefits for medical and subsistence needs.
- The OSG maintained that petitioner had means to support yet refused to do so, causing emotional distress.
Issues:
- Whether the Court of Appeals erred in convicting petitioner for violation of Section 5(e)(2), RA 9262, given his incapacity and lack of intent to control or restrict.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)