G.R. No. 232678 - Reyes vs. People

Case Summary (G.R. No. 232678)

Factual Background

AAA alleged that she and Reyes were married on May 15, 1969 and that four children were born of the union. She testified that Reyes provided monthly financial support ranging from Ten Thousand Pesos to Twenty Thousand Pesos but suddenly ceased such support in July 2005. At the time the complaint was filed, Reyes was employed abroad as a pilot. AAA further testified that her health deteriorated and that she suffered mental and emotional anguish as a result of the loss of financial support, and that she filed complaints because of that cessation of support and other related events.

Accusatory Instrument and Pretrial Orders

The Information dated June 5, 2006 charged that on or about July 2005 and continuously up to the present in Quezon City, the accused willfully, unlawfully and feloniously committed economic abuse upon his wife AAA by abandoning her without any financial support thereby depriving her of her basic needs and inflicting upon her psychological and emotional suffering. The RTC on March 12, 2007 issued a Temporary Protection Order directing Reyes to resume monthly financial support in the amount of P20,000 to be deducted from his net monthly salary. At the instance of AAA, a Hold Departure Order issued on August 30, 2007, and the TPO was made permanent on October 28, 2008.

Motion to Quash and Trial Court Ruling

Reyes moved to quash the Information on the ground that its allegations did not constitute the crime charged and thus violated his right to be informed of the nature and cause of the accusation. The trial court ruled on November 24, 2009 that the Information actually charged a violation of Section 5(i) of R.A. No. 9262, and directed the prosecutor to amend the designation of the offense. The trial court denied the motion to quash, arraigned Reyes, and, after trial, found him guilty in its March 3, 2016 Decision of violating Section 5(i), and sentenced him to an indeterminate term of three years of prision correccional as minimum to eight years and one day of prision mayor as maximum.

Evidence at Trial and Defense Case

The prosecution presented testimony from AAA, her attending physician, and her daughter, which the trial court found credible and sufficient to prove the elements of psychological violence under Section 5(i). The defense presented Reyes as its lone witness. He denied the validity of the marriage, alleged forgery of the marriage certificate, claimed a common-law relationship, and acknowledged past financial support but asserted he ceased support in July 2006 because AAA filed a bigamy case against him. He also claimed that he stopped flying in 2007 after the Hold Departure Order.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC Decision on June 23, 2017. The CA agreed that Reyes committed psychological violence by suddenly stopping financial support, thereby causing emotional and mental anguish to AAA. The CA held that the marriage is valid until annulled and that Reyes had an obligation to support his wife. The CA further observed that liability under Section 5(i) may be imposed even when the offender is not a spouse but has a sexual or dating relationship or a common child with the victim, and that Reyes could also, if properly indicted, be held liable under Section 5(e), paragraph 2 for depriving a woman of financial support legally due her.

Issues Raised in the Petition

In his petition for review, Reyes challenged the sufficiency of the Information and the legality of the trial court’s order to resume monthly support in the amount of P20,000, and he asserted that the facts alleged did not constitute the offense charged under Section 5(i) or Section 5(e), paragraph 2 of R.A. No. 9262. He maintained that the Information should have been quashed for failure to state an offense and for depriving him of due process.

Parties’ Contentions Before the Supreme Court

Reyes argued that the Information failed to allege the essential elements of the crime and thus warranted quashal under Section 6, Rule 110, Rules of Court. The Office of the Solicitor General countered that the Information sufficiently alleged economic abuse and psychological violence, that Reyes was properly charged, and that the evidence established guilt beyond reasonable doubt under Sections 5(e) and 5(i) of R.A. No. 9262.

Sufficiency of the Information — Legal Standard and Application

The Court reiterated the governing standard that an information is sufficient if it states the names of the accused; the designation of the offense by statute; the acts complained of; the name of the offended party; the approximate date; and the place of the offense, citing Section 6, Rule 110, Rules of Court. The Court applied the test that the facts alleged, if hypothetically admitted, must constitute the elements of the offense. Turning to the Information, the Court found that it plainly alleged that AAA was the wife of the accused, that she sustained mental and emotional anguish, and that such anguish resulted from the deliberate denial of financial support by Reyes. The Court concluded that these averments met the requirements to charge a violation of Section 5(i).

Elements of Psychological Violence and Proof

The Court adopted the elements of violation of Section 5(i) as articulated in Dinamling v. People: (1) the offended party is a woman and/or her child; (2) the woman is the wife or former wife of the offender or one with whom the offender has or had a sexual or dating relationship or a common child; (3) the offender causes mental or emotional anguish; and (4) such anguish is caused through acts enumerated in Section 5(i) including denial of financial support. Applying those elements to the record, the Court found that the prosecution proved each element by the clear and convincing testimonies of AAA and her daughter showing the cessation of support from July 2005 and the resultant emotional and physical effects on AAA.

Validity of the Marriage and Obligation to Support

On the claim that no valid marriage existed, the Court found that the certified copy of the marriage contract admitted by the prosecution constituted positive evidence of the marriage celebrated on May 15, 1969, and is entitled to full faith and credence. The Court emphasized that a marriage is valid until judicially declared otherwise and that Reyes therefore had an obligation to support AAA in proportion to his means and her needs. The Court further observed that even if a marriage were void, R.A. No. 9262 penalizes violence committed by persons who have or had a sexual or dating relationship with the victim or with whom the victim has a common child.

Economic Abuse under Section 5(e) and Mens Rea for Deprivation

The Court discussed Section 5(e), paragraph 2, noting that deprivation or denial of support to which the woman is legally entitled is specifically criminalized. The Court found that Reyes deliberately refused to provide financial support despite gainful employment after June 2005 and that his stated motive—retaliation for the filing of a bigamy case—did not excuse him. The Court agreed with the CA that the denial of financial support was designed to control or subjugate AAA’s conduct, including to deter or coerce her regarding her criminal complaints against him.

Relief, Penalty and Directions

Having found Reyes guilty beyond reasonable doubt of violating Section 5(i), the Court imposed an indeterminate penalty of four years and two months of prision correccional as minimum to eight years and one day of prision mayor as maximum. The Court directed Reyes to pay a fine of Two Hundred Thousand Pesos (P200,000.00) and to undergo mandatory psychological counseling or psychiatric treatment and to report compliance to the court of origin within fifteen days after completion. The Court also affirmed that Reyes must comply with the TPO directive to resume monthly financial support to AAA, noting absence of evidence that he lacked employment or means.

Legal Basis and Reasoning

The Court grounded its decis

Case Syllabus (G.R. No. 232678)

Parties and Procedural Posture

Petitioner Esteban Donato Reyes filed a petition for review on certiorari from the Court of Appeals decision affirming his conviction.
Respondent People of the Philippines prosecuted Reyes for violation of Section 5(i) of R.A. No. 9262.
The case originated as Criminal Case No. Q-06-143139 in the Regional Trial Court, Branch 89, Quezon City, which rendered a decision on March 3, 2016.
The Court of Appeals affirmed the RTC decision by its June 23, 2017 judgment in CA-G.R. CR No. 38609.
The Supreme Court denied the petition and affirmed the conviction with modifications to the penalty and ancillary orders.

Key Factual Allegations

AAA and Reyes lived as spouses and allegedly contracted marriage on May 15, 1969, which produced four children.
AAA alleged that Reyes provided monthly financial support ranging from Ten Thousand Pesos to Twenty Thousand Pesos until he suddenly ceased support in July 2005.
AAA alleged that she suffered multiple illnesses and that the cessation of support aggravated her health and caused mental and emotional anguish.
Reyes admitted to giving financial support but asserted he stopped in July 2006 because AAA filed a bigamy case against him.
Reyes asserted that his marriage to AAA was invalid and that his signature on the marriage certificate was forged.

Charges and Information

An Information dated June 5, 2006 and filed on September 26, 2006 charged Reyes initially under Section 5(e), par. 2 of R.A. No. 9262 for economic abuse.
The accusatory portion alleged that Reyes, in or about July 2005 and continuously thereafter, abandoned his wife AAA without financial support thereby depriving her of basic needs and inflicting psychological and emotional suffering.
The RTC ruled on November 24, 2009 that the facts in the Information actually charged Section 5(i) of R.A. No. 9262 and directed amendment of the Information since Reyes had not yet been arraigned.

Pretrial Orders

On March 12, 2007 the RTC issued a Temporary Protection Order directing Reyes to resume monthly financial support of P20,000, to be deducted from his net monthly salary of US$2,500 from the time it was withheld.
Upon motion by AAA and with prosecutor conformity, the RTC issued a Hold Departure Order on August 30, 2007.
The March 12, 2007 Temporary Protection Order was made permanent by the RTC on October 28, 2008.

Trial Evidence

The prosecution presented testimony from AAA, her attending physician Dr. Rey Caesar R. Anunciacion, and AAA's daughter to establish cessation of support and resultant mental and emotional suffering.
The prosecution offered a certified copy of the marriage certificate as public documentary evidence of the marital relationship.
The defense presented Reyes as its lone witness who disputed the validity of the marriage and testified to his prior provision of financial support and his cessation of support following the filing of a bigamy case.

Trial Court Findings

The RTC found the prosecution witnesses credible and sufficient to prove all elements of Section 5(i) of R.A. No. 9262 beyond reasonable doubt.
The RTC denied Reyes' Motion to Quash and found that the Information, as amended, properly charged Section 5(i).
The RTC convicted Reyes and originally sentenced him to an indeterminate penalty of three