G.R. No. 193225 - BBB vs. AAA

Case Summary (G.R. No. 193225)

Key Dates

– 1996: BBB and AAA begin serious dating
– October 10, 2002: Civil marriage; legitimation of children’s birth certificates
– August 14, 2007: RTC issues Permanent Protection Order (PPO) under R.A. 9262
– November 6, 2009: CA Decision affirming PPO with modification
– August 3, 2010: CA Resolution denying reconsideration
– February 9, 2015: Supreme Court Decision

Applicable Law

– 1987 Philippine Constitution
– Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004)
– A.M. No. 04-10-11-SC (Rule on Violence Against Women and Their Children)
– A.M. No. 10-4-16-SC (Court-Annexed Family Mediation)
– Family Code: Articles 177–179 (legitimation), Article 213 (custody)
– New Civil Code: Article 1431 (estoppel)
– Rules of Court, Rule 45 (petition for review on certiorari)

Antecedent Facts

AAA alleged that BBB subjected her and their children to psychological, emotional, and economic abuse: verbal insults, public humiliation via his mistress (FFF), stalking through a third party, and failure to pay rent and adequate support. BBB countered that AAA’s irrational jealousy and her unilateral departure from the conjugal home caused their estrangement and financial strain. AAA filed for a Temporary Protection Order (TPO) and later sought to make it permanent under R.A. 9262.

RTC Proceedings and Orders

The RTC found sufficient grounds for abuse and issued a Permanent Protection Order on August 14, 2007, which:

Prohibited BBB from stalking, harassing, or verbally abusing AAA;
Forbade exposing minor children to immoral companions, including FFF;
Granted AAA permanent sole custody and limited BBB to one supervised visit per month for two years;
Directed BBB to continue AAA’s possession of the family vehicle;
Ordered support of ₱62,918.97 monthly (inclusive of education, medical, etc.);
Required BBB to post a ₱300,000 bond for peace and pay ₱100,000 in attorney’s fees and litigation costs;
Mandated BBB keep a 100-meter distance from AAA and designated places she frequents.

Court of Appeals Ruling

The CA, on November 6, 2009, affirmed the RTC’s findings of psychological, emotional, and economic abuse under R.A. 9262 and its award of support and protective measures. It modified the custody order by remanding to the RTC the determination of custodianship, noting that children over seven may choose. The CA denied BBB’s partial reconsideration on August 3, 2010.

Issues on Review

BBB’s Rule 45 petition raised these principal legal questions:

Whether the CA erred in upholding the permanent protection order;
Whether the award of attorney’s fees and litigation costs was excessive;
Whether the bond requirement was excessive;
Whether unauthenticated text messages should have been admitted;
Whether support orders should be deleted since BBB purportedly obtained actual custody of DDD and EEE and CCC is not his biological child.

Supreme Court Analysis

– Compromise Prohibition: Cases under R.A. 9262 are non-compromisable; violence against women cannot be mediated or compromised.
– Factual Findings: The petition improperly sought re-evaluation of RTC and CA factual determinations, beyond the scope of Rule 45, which only entertains legal questions.
– Text Messages: BBB admitted authorship in pleadings, rendering any authentication issue moot.
– Legitimation and Support: Despite CCC’s non-biological origin, BBB’s voluntary legitimation estops him from denying paternity; CCC is entitled to equal support under Family Code Articles 177–179.
– Post-PPO Circumstances: Subsequent custody arrangements do not nullify the PPO; any modification of visitation or support depends on the custody outcome, not on mootness of the protective order.

Supreme Court Conclusion and Order

Case Syllabus (G.R. No. 193225)

Antecedent Facts

BBB and AAA first met in 1991, began a serious relationship in 1996; AAA was a medical student raising her son CCC from a previous relationship.
During their relationship, AAA bore two more children: DDD (born December 11, 1997) and EEE (born October 19, 2000).
BBB and AAA married in October 2002, legitimating all three children under BBB’s name.
Marital relations deteriorated amidst mutual accusations: BBB blamed AAA’s alleged jealousy and frequent arguments; AAA accused BBB of womanizing, public humiliation by his alleged mistress FFF, and biased treatment of CCC.
AAA claimed economic abuse when BBB neglected condominium rent and provided insufficient support, forcing her to work and borrow money.
AAA alleged psychological abuse and stalking: BBB allegedly used a friend, GGG, to monitor AAA’s movements and those of their children.

Procedural Posture

AAA filed for a Temporary Protection Order (TPO) under R.A. No. 9262, which the RTC of Pasig City issued and subsequently made permanent on August 14, 2007.
BBB appealed to the Court of Appeals (CA) under Rule 45, challenging the PPO’s issuance, custody award, bond amount, attorney’s fees, and admissibility of text messages.
On November 6, 2009, the CA affirmed with modification, notably ordering a remand for custody determination; its resolution of August 3, 2010 denied BBB’s motion for partial reconsideration.
BBB filed a Petition for Review on Certiorari with the Supreme Court, reiterating factual grievances and raising new arguments, including mootness due to subsequent events and a purported Memorandum of Agreement (MOA) on custody and support signed in 2013.

Issues Presented

Whether the CA erred in affirming the RTC’s decision to make the TPO permanent.
Whether the CA erred in upholding the award of attorney’s fees and costs in AAA’s favor.
Whether the CA erred in affirming the requirement for BBB to post an excessive bond to keep the peace.
Whether the RTC and CA correctly admitted unauthenticated text messages as evidence.
Whether the support award should be deleted because DDD and EEE allegedly remain i