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

Case Summary (G.R. No. 232678)

Procedural Posture

An Information initially designated as charging violation of Section 5(e), paragraph 2 of RA 9262 was filed against Reyes. The trial court, upon motion and before arraignment, concluded the facts alleged stated an offense under Section 5(i) (psychological violence) and directed amendment to properly designate the offense; the Motion to Quash was denied. After trial, the Regional Trial Court (RTC) found Reyes guilty under Section 5(i) and imposed an indeterminate penalty (minimum three years prision correccional to maximum eight years and one day prision mayor). The Court of Appeals (CA) affirmed. Reyes filed a petition for review on certiorari to the Supreme Court, raising, inter alia, insufficiency of the Information and contesting guilt and sentence.

Factual Background

AAA and Reyes allegedly entered into marriage on May 15, 1969 and had four children (three surviving). Reyes served as a Philippine Air Force pilot and later as a commercial pilot; at the time of complaint he worked abroad. AAA testified Reyes provided monthly support (P10,000–P20,000) but ceased giving support abruptly in July 2005. AAA alleged that the cessation of support led to mental and emotional anguish and aggravated health conditions requiring ongoing medical care. Reyes admitted providing financial support previously but asserted he stopped in either July 2006 (per his testimony) because AAA filed a Bigamy complaint against him; he also disputed the validity of the marriage, alleging forgery and asserting a common‑law relationship.

Pre‑trial Protective and Enforcement Measures

The RTC issued a Temporary Protection Order (March 12, 2007) directing Reyes to resume delivery of monthly financial support of P20,000, to be deducted from his net monthly salary of US$2,500, reckoned from when support was withheld. The trial court later made the TPO permanent (October 28, 2008). The HDO (August 30, 2007) prevented Reyes from leaving the country.

Motion to Quash and Trial Court Ruling on the Information

Reyes moved to quash the Information arguing the allegations did not constitute an offense under Section 5(e), par. 2 (distinguishing “abandoning without financial support” from deprivation/denial of support). The prosecution opposed. The RTC held that, based on the Information’s allegations, the charge was properly characterized as violation of Section 5(i), not Section 5(e), par. 2, and ordered formal amendment before arraignment. The Motion to Quash was denied and Reyes pleaded not guilty to Section 5(i).

Prosecution Evidence at Trial

The prosecution presented AAA, her attending physician, and AAA’s daughter. Their testimonies established the marital relationship, cessation of financial support from July 2005 onward, AAA’s deteriorating health and dependence on maintenance medicines and treatment, and the mental and emotional suffering she experienced because of the deprivation of support. AAA’s testimony indicated the cessation of support was the primary reason for filing the VAWC complaint.

Defense Evidence at Trial

Reyes testified as sole defense witness. He challenged the marriage’s validity (claiming non‑attendance at the ceremony and forgery of his signature and erroneous age in the certificate), admitted prior provision of regular support and additional assistance (medical, educational, vacations), and asserted he ceased support because AAA filed a Bigamy case against him. He also stated he had been prevented from leaving the country in 2007 by the HDO and stopped flying in 2007.

RTC Decision and Findings

The RTC found the prosecution witnesses credible and sufficient to prove all elements of Section 5(i) (psychological violence) beyond reasonable doubt. The RTC concluded that Reyes’ denial of financial support caused AAA mental and emotional anguish and thus constituted psychological violence under Section 5(i). The RTC sentenced Reyes to an indeterminate term of three years prision correccional as minimum to eight years and one day prision mayor as maximum.

Court of Appeals Ruling

The CA affirmed the RTC, agreeing that Reyes committed psychological violence by suddenly stopping financial support, causing emotional and mental anguish to AAA. The CA emphasized Reyes’ obligation to support his wife while the marriage remains valid and rejected the contention that lack of marital status would absolve him because RA 9262 protects women in other intimate relationships as well. The CA also observed that Reyes could be liable under Section 5(e), par. 2 (economic abuse) had he been indicted under that provision.

Issues Raised to the Supreme Court

Reyes raised primarily: (1) the alleged error in ordering him to resume payment of P20,000 monthly (deducted from salary) reflecting the TPO; and (2) that the Information was defective and should have been quashed for failing to allege the elements of Section 5(i) (thereby violating due process and right to be informed of the accusation), and consequently that his conviction should be reversed.

Legal Standard on Sufficiency of an Information

The Court reiterated the requisites under Section 6, Rule 110: an information must state the accused’s name, statutory designation of the offense, acts or omissions constituting the offense, name of offended party, approximate date, and place. The fundamental test is whether the facts alleged, if assumed true, constitute the elements of the alleged offense so as to inform the accused of the nature and cause of the accusation.

Elements of Section 5(i) and Application to the Information

The Supreme Court summarized the elements of Section 5(i): (1) the offended party is a woman and/or her child; (2) relationship between offender and woman (wife/former wife; sexual/dating relationship; common child); (3) offender causes mental or emotional anguish; and (4) anguish is caused through acts such as public ridicule, repeated verbal/emotional abuse, denial of financial support, denial of custody/access, or similar acts/omissions. The Court found the June 5, 2006 Information sufficiently alleged these elements by stating AAA was the wife, that Reyes abandoned her without financial support depriving her of basic needs, and that such deprivation inflicted psychological and emotional suffering.

Findings on Marriage Validity and Obligation to Support

The Court accepted the certified copy of the marriage certificate as positive proof of marriage, accorded full faith and credence to the public document, and held the marriage valid until judicially declared otherwise. Consequently, Reyes had a legal obligation to support AAA. The Court also noted that even if the marriage were declared void, RA 9262 covers other intimate relationships (sexual or dating relationships or common‑child situations), so liab

Case Syllabus (G.R. No. 232678)

Case Caption and Nature of Review

Petition for review on certiorari filed by petitioner Esteban Donato Reyes seeking reversal and setting aside of the June 23, 2017 Decision of the Court of Appeals in CA-G.R. CR No. 38609.
The CA decision affirmed the March 3, 2016 Decision of the Regional Trial Court, Branch 89, Quezon City (Criminal Case No. Q-06-143139), which found Reyes guilty beyond reasonable doubt of Violation of Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004), committed against AAA.

Antecedent Facts

An Information dated June 5, 2006 was filed on September 26, 2006 before the RTC charging Reyes, initially designated as violation of Section 5(e), paragraph 2 of R.A. No. 9262.
On March 12, 2007 the RTC issued a Temporary Protection Order (TPO) directing Reyes to resume monthly financial support to AAA in the amount of P20,000.00 to be deducted from his net monthly salary of US$2,500.00, reckoned from the time it was withheld in July 2005.
Upon motion of AAA, with the conformity of the public prosecutor, the RTC issued on August 30, 2007 a Hold Departure Order (HDO) against Reyes.
On October 28, 2008 the RTC made the March 12, 2007 TPO permanent.

Motion to Quash and Pretrial Procedural History

On June 11, 2009 Reyes filed a Motion to Quash the Information, arguing that the allegations did not constitute violation of Section 5(e), par. 2 and that “abandoning without financial support” is not criminalized under R.A. No. 9262; he argued deprivation or denial is distinct and essential elements were not charged.
The prosecution opposed the Motion to Quash, maintaining that the totality of facts constituted the crime of violation of Section 5(e), par. 2.
In an Order dated November 24, 2009, the RTC ruled that the Information actually charged violation of Section 5(i) of R.A. No. 9262, directed the Office of the City Prosecutor to amend the Information to designate the proper crime, and denied the Motion to Quash.
The RTC held the amendment was proper and formal, noting Reyes had not yet been arraigned; arraignment followed and Reyes pleaded not guilty to violation of Section 5(i).

Relevant Facts Presented at Trial

AAA and Reyes were married on May 15, 1969; their union produced four children, three of whom are living and are of legal age.
Reyes had prolonged absences from home due to military service as a Philippine Air Force pilot and later employment as a commercial pilot for Philippine Airlines; at the time the complaint was filed he was employed as a pilot based in Angola, Africa delivering relief goods by air.
AAA claimed Reyes provided monthly financial support ranging from P10,000.00 to P20,000.00 but suddenly ceased giving the same in July 2005.
AAA suffered various illnesses including hypertension, cardiovascular disease, diabetes and osteoarthritis; her advancing age required maintenance medicines and regular medical care.
AAA stated that Reyes’s failure to provide monthly financial support compelled her to file the complaint under R.A. No. 9262.
Reyes testified as the lone defense witness and contested the validity of the marriage, alleging he never attended the ceremony and that his signature on the marriage certificate was forged; he also claimed the age on the certificate was erroneous.
Reyes averred a common-law relationship with AAA producing three daughters and a son, and admitted providing past financial support and other assistance; he claimed he stopped financial support in July 2006 (he also alternatively stated July 2005 elsewhere in the proceedings) because AAA filed a Bigamy case against him.
Reyes admitted he stopped flying in 2007 after being prevented from leaving the Philippines due to the Hold Departure Order.

RTC Decision and Findings

The RTC, after trial, rendered its Decision dated March 3, 2016 finding Reyes GUILTY beyond reasonable doubt of violating Section 5(i) of R.A. No. 9262.
The RTC sentenced Reyes to an indeterminate penalty of three (3) years of prision correccional as minimum, to eight (8) years and one (1) day of prision mayor as maximum.
The RTC found the testimonies of AAA, her attending physician Dr. Rey Caesar R. Anunciacion, and AAA’s daughter credible and sufficient to establish all elements of Section 5(i) violation.

Court of Appeals Decision

On June 23, 2017 the CA rendered its Decision affirming the RTC’s conviction and sentence in CA-G.R. CR No. 38609 and dismissed Reyes’s appeal for lack of merit.
The CA agreed that Reyes committed psychological violence against AAA when he suddenly stopped giving financial support, causing emotional and mental anguish.
The CA held Reyes had an obligation to financially support AAA because their marriage is valid until annulled; the CA further held that violation of Section 5(i) can be committed even against a woman with whom the accused had a sexual or dating relationship or a common child.
The CA opined Reyes could also be convicted under Section 5(e) if properly indicted, since that provision penalizes deprivation of financial support legally due.

Issues Raised in the Petition to the Supreme Court

Whether the CA committed reversible error when affirming the RTC’s directive ordering Reyes to resume giving regular monthly financial support to AAA in the amount of P20,000.00, to be deducted from his net monthly salary, reckoned from the time it was withheld in July 2005.
Whether the CA committed reversible error in affirming the RTC’s conviction of Reyes beyond reasonable doubt for violation of Section 5(i) of R.A. No. 9262 and imposing the indeterminate penalty of three (3) years prision correccional to eight (8) years and one (1) day prision mayor.

Petitioner’s Principal Arguments

Reyes insisted the June 5, 2006 Information failed to allege acts punishable under either Section 5(e), par. 2 or Section 5(i) of R.A. No. 9262 and should have been quashed for lack of essential elements, thereby depriving him of due process and the right to be informed of the nature and cause of the accusation.
Reyes argued he could not be held liable under R.A. No. 9262 because he had no obligation to support AAA, contending they never contracted marriage.

Prosecution / Office of the Solicitor General (OSG) Position

The OSG maintained the Information, read in its entirety, charged Reyes under Section 5(e), par. 2 for economic abuse by abandoning or failing to give financial support.
The OSG supported the CA’s affirmation that Reyes was properly convicted under Section 5(i), and that criminal liability could also attach under Section 5(e), par. 2 because deprivation of support was intended to deter AAA from filing or pursuing cases against him.
The OSG asserted the guilt of Reyes for viola