Title
Supreme Court
XXX60504 vs. AAA260504
Case
G.R. No. 260504
Decision Date
Nov 13, 2023
The case involved an appeal concerning civil liability for child support despite acquittal of psychological abuse charges under the Anti-Violence Against Women Act, remanding it for proper accounting of support due.

Case Digest (G.R. No. 260504)
Expanded Legal Reasoning Model

Facts:

  • Parties and Charges
    • XXX260504 (Petitioner) was charged with violation of Section 5(i) of Republic Act No. 9262, the Anti-Violence Against Women and Their Children Act of 2004.
    • The charge alleged that from April 11, 2006, to the present, XXX260504, then the boyfriend of AAA260504 (private complainant), deliberately caused psychological and economic abuse by refusing to provide financial support to AAA260504 and their minor child BBB260504.
  • Trial Proceedings
    • XXX260504 pleaded not guilty upon arraignment.
    • The prosecution presented witnesses AAA260504 and CCC260504; however, their testimonies did not sufficiently prove the deliberate refusal or denial of support.
    • XXX260504 filed a Motion for Leave to File Demurrer to Evidence, arguing insufficient evidence and lack of proof of psychological abuse or willful refusal to support.
  • RTC Decision
    • The Regional Trial Court (RTC) granted the demurrer to evidence, acquitting XXX260504 of the criminal charge due to reasonable doubt.
    • Nevertheless, the RTC held that XXX260504 was civilly liable to pay monthly support of USD 100 or its peso equivalent to their minor child from April 2006 to June 2018.
  • Subsequent Motions and Appeal
    • XXX260504 filed a Motion for Partial Reconsideration, claiming the award of civil liability was baseless, violated due process, and should not be based on ex delicto civil liability.
    • The RTC denied this motion.
    • XXX260504 appealed to the Court of Appeals (CA), asserting errors in fixing the amount of support without due process and awarding civil liability despite acquittal.
    • The CA reversed the RTC’s award of civil liability due to lack of evidence on the accused’s financial capacity and remanded for proper determination.
    • Both parties filed motions for reconsideration which were denied by the CA.
  • Petition to the Supreme Court
    • XXX260504 petitioned for review, arguing the CA erred in affirming civil liability and in applying RA 9262.
    • AAA260504 opposed, urging denial of the petition.

Issues:

  • Whether the Court of Appeals erred in affirming the civil liability of XXX260504 for child support despite his acquittal of the criminal charge based on reasonable doubt.
  • Whether due process was violated in awarding civil support without allowing XXX260504 to present evidence of his financial capacity.
  • Whether the trial court had jurisdiction to award civil liability in a criminal case under RA 9262 or whether a separate civil action is necessary.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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