Case Summary (G.R. No. 232678)
Petitioner
Esteban Donato Reyes, accused of economic and psychological violence under R.A. No. 9262 for withdrawing financial support from his wife, AAA, beginning July 2005.
Respondent
People of the Philippines, prosecuting the alleged violation of Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004).
Key Dates
• June 5, 2006 – Information filed for violation of Section 5(e), par. 2, R.A. No. 9262.
• March 12, 2007 – Temporary Protection Order (TPO) directing support of ₱20,000/month.
• August 30, 2007 – Hold Departure Order issued against Reyes.
• October 28, 2008 – TPO made permanent.
• March 3, 2016 – RTC conviction under Section 5(i).
• June 23, 2017 – CA affirmed RTC decision.
• July 3, 2019 – Supreme Court decision.
Applicable Law
• 1987 Philippine Constitution (due process, right to information).
• Republic Act No. 9262, Sections 3(c), 5(e)(2), 5(i), and Section 6(f) on penalties.
• Rule 110, Section 6 of the Rules of Court on sufficiency of Information.
• Indeterminate Sentence Law (Art. 64, RPC).
Procedural History
The RTC denied Reyes’s motion to quash, found him guilty beyond reasonable doubt of Section 5(i) RA 9262, and sentenced him to 3 years prision correccional to 8 years and 1 day prision mayor. The CA dismissed his appeal. Reyes filed a petition for certiorari with the Supreme Court.
Facts
Reyes and AAA married in 1969 and had four children. Beginning July 2005, while assigned abroad, Reyes ceased remitting ₱10,000–₱20,000 monthly support. AAA’s health deteriorated, prompting her to seek relief under R.A. No. 9262. Reyes claimed the marriage was void and support terminated out of “ingratitude.”
Issues
- Whether the June 5, 2006 Information sufficiently alleged the elements of Section 5(i).
- Whether Reyes’s marital relationship and corresponding support obligation were valid.
- Whether deprivation of financial support constitutes psychological violence under Section 5(i) or economic abuse under Section 5(e)(2).
Legal Analysis
– Under Rule 110, Sec. 6, an Information must state the accused’s name, statutory designation of the offense, acts or omissions, offended party, date, and place. The Information alleged abandonment without support, causing psychological and emotional suffering, meeting Section 5(i) elements.
– Section 5(i) requires (a) the offended party be a spouse or person with a sexual relationship; (b) mental or emotional anguish; and (c) anguish resulting from denial of financial support or similar acts. These elements were adequately pleaded.
– The certified marriage contract is admissible best evidence establishing Reyes’s marital status and his legal duty to support. A marriage is valid until judicially annulled. Even absent a valid marriage, RA 9262 covers persons with whom the offender has a common child. AAA bore Reyes four children.
– Deprivation of support also constitutes economic abuse under Section 5(e)(2), which penalizes depriving a
Case Syllabus (G.R. No. 232678)
Antecedent Facts
- An Information dated June 5, 2006 (filed September 26, 2006) charged Reyes with violation of Section 5(e), paragraph 2, R.A. No. 9262 (economic abuse).
- RTC issued a Temporary Protection Order (TPO) on March 12, 2007 directing Reyes to pay ₱20,000 monthly support, to be deducted from his US$2,500 salary.
- On August 30, 2007, the RTC granted a Hold Departure Order (HDO) against Reyes; on October 28, 2008, the TPO was made permanent.
- Reyes moved to quash the Information (June 11, 2009), arguing “abandoning without financial support” is not penalized by R.A. No. 9262; RTC denied the motion.
- RTC, on November 24, 2009, ruled that Reyes was charged under Section 5(i) (psychological violence) instead of Section 5(e), paragraph 2, and ordered the City Prosecutor to amend the Information; Reyes pleaded not guilty to Section 5(i).
Prosecution Evidence
- Reyes and AAA were validly married on May 15, 1969; they had four children, three surviving and now of legal age.
- Reyes worked as an Air Force pilot, later a commercial pilot for Philippine Airlines, and at the time of filing was based in Angola delivering relief goods.
- In 2005 Reyes married Marilou Osias Ramboanga and fathered four more children.
- Reyes ceased all financial support to AAA in July 2005.
- AAA’s health deteriorated (hypertension, cardiovascular disease, diabetes, osteoarthritis), requiring maintenance medicines and recurring consultations.
- AAA filed the VAWC complaint primarily because Reyes failed to provide mandated monthly support.
Defense Evidence
- Reyes denied a valid marriage to AAA, claiming a common-law relationship and alleging forgery on the marriage certificate.
- He admitted giving AAA ₱20,000 monthly, plus various medical and educational expenses, but stopped in July 2006 out of resentment over AAA’s Bigamy case.
- He contended no legal obligation to support AAA since, in his view, no valid marriage existed.
RTC Decision (March 3, 2016)
- Found Reyes guilty beyond reasonable doubt of violating Section 5(i), R.A. No. 9262 (psychological violenc