Case Summary (G.R. No. 264846)
Background and Family History
CCC married III in 2006, and they had two children, AAA and BBB. After seven years, the marriage dissolved due to personal differences; III separated and lived with her parents in North Cotabato. In 2014, the marriage was legally terminated through a divorce granted by a Shari’a Court. III passed away three years later (2017). Following her death, the minors were placed in the care of III’s relatives—respondents—including EEE, who was appointed by the court as the guardian despite working abroad, consistently remitting financial support.
Petition for Habeas Corpus and Custody
In 2018, CCC located his children living with their maternal relatives in a city apartment. He filed a petition for habeas corpus seeking to gain custody of the children. The Court of Appeals initially referred the case to the RTC, ordering the maternal relatives to justify why they should retain custody rather than return the minors to CCC.
Testimonies of the Minors
AAA testified that CCC physically abused him, his sister, and their late mother. He described an incident where CCC threatened III’s life and expressed animosity by denying paternity and the legitimacy of the marriage. AAA preferred living with his maternal relatives, expressing hatred toward CCC. BBB’s testimony corroborated AAA’s account; she preferred to stay with her aunts and uncles, citing kindness and CCC’s formation of a new family as reasons to be reluctant to live with him.
Respondents’ Position and Guardian’s Role
Respondents asserted their custodial role following III’s death, with EEE officially appointed guardian and providing financial support. They emphasized CCC’s inability to provide proper care due to his past conduct and highlighted the hardships III endured.
CCC’s Counter-Arguments
CCC denied abandonment allegations and claimed his new relationship commenced only after separating from III. He accused respondents of alienating the children and asserted his capability and willingness to care for and guide them, including with the consent of his new wife willing to accept the children into their home.
RTC Decision
The RTC denied CCC’s petition, ordering that custody remain with EEE in the interest of the minors' welfare. CCC was directed to provide a monthly financial support of PHP 40,000 (matching EEE's support). The court mandated counseling for the children and petitioner to facilitate readiness for visitation and gradual reestablishment of their relationship. Visitation rights were conditioned on the children’s emotional preparedness and the Social Welfare Officer’s recommendations.
RTC Rationale
The court prioritized the best interest and welfare of the children, noting their expressed preference to remain with maternal relatives. The decision reflected the principle of preserving the status quo when in the children’s best interest.
Court of Appeals Affirmation
The CA upheld the RTC’s ruling, considering all circumstances relevant to the children’s well-being. It affirmed that respondents had the better right to custody and that EEE had not unlawfully restrained the minors' liberty.
Supreme Court Analysis and Final Ruling
The Supreme Court, applying the 1987 Constitution and relevant rules, found no reversible error in the lower courts’ decisions. The essence of a writ of habeas corpus in custody cases extends beyond producing the child before courts to determining rightful custody based on the child’s best interest. The Court emphasized that custody issues are primarily factual, and under Rule 45, it defers to trial courts’ findings except in cases of grave abuse of discretion.
The Court acknowledged the minors’ negative sentiments toward CCC, largely due to alleged prior abuses and emotional rejection. The children’s preference to live with maternal relatives was a crucial factor. It further recognized that EEE, as the court-appointed guardian, had been fulfilling his duties responsibly with continued financial support and care.
Legal Framework on Custody Considerations
Section 14 of A.M. No. 03-04-04-SC outlines the factors for custody determination focusing primarily on the best interest of the child, defined in physical, psychological, emotional, and educational terms. It mandates consideration of:
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Case Syllabus (G.R. No. 264846)
Facts and Antecedents
- CCC married III in 2006, with whom he had two children: AAA (born 2006) and BBB (born 2011).
- After seven years, marital relationship deteriorated, prompting III to leave with their children and seek refuge with her family in North Cotabato.
- The marriage was legally dissolved through a Shari’a Court divorce in 2014.
- III passed away three years later, leaving AAA and BBB under the care of III’s relatives—respondents in this case.
- Respondent EEE, III’s brother, was judicially appointed guardian of the minors.
- In 2018, CCC discovered that his children were living in an apartment with III’s siblings, no longer in North Cotabato.
- CCC filed a petition for habeas corpus with the Court of Appeals (CA) to regain custody of the minors.
- The CA referred the case to the Regional Trial Court (RTC) Branch xxxxxxx in Cotabato for trial, ordering III’s siblings and the children to appear and show cause why the children should not be returned to CCC.
Testimonies and Factual Findings
- AAA testified about physical abuse by CCC towards him, BBB, and their late mother III, including a specific threat CCC made to III’s life.
- AAA expressed a preference to live with his mother’s relatives rather than with CCC, articulating feelings of hatred toward his father.
- BBB corroborated her brother’s testimony, desiring to stay with her aunts and uncles who had treated her kindly and expressing reluctance due to CCC’s new family situation.
- Respondents confirmed their care for the children following III’s death and that EEE had petitioned for guardianship.
- EEE regularly provided PHP 40,000 monthly for the children’s needs, despite working abroad.
- Respondents questioned CCC’s capability to provide proper care, highlighting hardships suffered by III during her marriage.
- CCC denied abandoning III and the children for another woman and claimed his new relationship began only after separating from III.
- CCC alleged respondents influenced his children against him and affirmed his wish to personally raise the children.
- CCC contended his new wife agreed to care for the minors.
RTC Ruling and Judgment
- The RTC denied CCC’s petition for habeas corpus and custody, affirming custody remains with EEE, the court-appointed guardian.
- The RTC ordered CCC to provide monthly financial support of PHP 40,000 for the children’s support, maintenance, and education