Case Summary (G.R. No. 221370)
Petitioner
XXX, father of BBB and former husband of AAA, charged with economic abuse for willful deprivation of financial support.
Respondent
People of the Philippines, through the Office of the Solicitor General.
Key Dates
– August 2005: Birth of BBB
– December 2, 2013: RTC conviction
– November 3, 2015: CA decision affirming conviction
– June 28, 2021: Supreme Court decision under the 1987 Constitution
Applicable Law
– 1987 Philippine Constitution (post-1990 decisions)
– Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act), Section 5(e)(2) (economic abuse)
– Family Code Articles 194, 195, and 201 (parental support obligations)
Antecedents
An information was filed charging XXX with violation of RA 9262 Section 5(e)(2) for depriving AAA and BBB of sufficient financial support from August 2005 onward. XXX pleaded not guilty, and trial ensued before RTC Branch 199 of xxxxxxxxxxx City.
Prosecution’s Evidence
AAA recounted their marriage in March 2005, separation after two months, and BBB’s diagnosis of Congenital TORCH Syndrome requiring a hearing aid (P35,000) and specialized education (tuition P20,000). She testified that XXX provided minimal support (five payments totaling about P10,000) only after the prosecutor’s recommendation. Danielle Joanne Raymundo, a speech-language pathologist, confirmed BBB’s profound hearing loss and recommended early cochlear implantation and weekly therapy. AAA’s mother, DDD, corroborated AAA’s account of sporadic support and ongoing fundraising for BBB’s medical needs.
Defense’s Evidence
XXX denied intent to deprive support, alleging emotional and physical abuse by AAA and claiming that AAA forced a “kasunduan” for their separation. He presented receipts of support payments from 2010 to 2013 and asserted he bore initial hospital expenses (P25,000). He argued limited income (monthly salary ~P16,000) and wife’s interference prevented full compliance until angered by AAA’s failure to facilitate visits in 2008.
RTC Decision
The RTC found XXX guilty beyond reasonable doubt of economic abuse under RA 9262 Section 5(e)(2). It held that:
- All elements of deprivation of legally due support were established.
- Prior support was insufficient given BBB’s medical and educational needs.
- XXX’s motive was ire against AAA, not inability to pay.
- His belated support began only after formal charge.
Sentence: Six months and one day of prisión correccional, fine of ₱100,000, moral damages of ₱10,000, mandatory psychological counseling, and indemnification.
Court of Appeals Ruling
The CA denied XXX’s appeal, affirming the RTC’s findings and penalty. It agreed that factual findings were supported by evidence and that economic abuse was proven.
Issues for Supreme Court Review
XXX contested (a) sufficiency of support documentation; (b) voluntariness of separation agreement; and (c) absence of malice or intent. The People argued that the petition raised purely factual questions and failed to refute elements of economic abuse.
Supreme Court Ruling
- Rule 45 review is limited to questions of law; facts affirmed by RTC and CA are conclusive absent recognize
Case Syllabus (G.R. No. 221370)
Procedural History
- An Information was filed against petitioner XXX for violation of Section 5(e)(2) of RA 9262 (Anti-Violence Against Women and Their Children Act of 2004) before the RTC of [blotted out] City, Branch 199, in Criminal Case No. 11-0139.
- Upon arraignment, XXX pleaded not guilty and trial on the merits ensued.
- On December 2, 2013, the RTC rendered a decision finding XXX guilty beyond reasonable doubt and imposing a penalty of six months and one day of prisión correccional, a ₱100,000 fine, moral damages of ₱10,000, and mandatory psychological counseling.
- XXX appealed to the Court of Appeals (CA), which on November 3, 2015, in CA-G.R. CR No. 36620, affirmed the RTC decision in toto.
- XXX then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, assailing only questions of law.
Factual Background
- AAA and XXX were high-school acquaintances who began dating in college; AAA became pregnant and they married on March 8, 2005, subsequently living in XXX’s family home.
- After an argument in late pregnancy—when petitioner allegedly refused to procure medical care—AAA left and returned to her parents’ residence.
- On August 2, 2005, AAA gave birth to their son, BBB, who was diagnosed with Congenital TORCH Syndrome, resulting in delayed development and bilateral profound hearing loss.
- A medical specialist recommended a hearing aid (approximate cost ₱35,000) and later a cochlear implant (approximate cost ₱1,000,000 per ear) for BBB’s optimal development.
Prosecution Evidence
- AAA testified that XXX repeatedly refused to provide financial support for medical and educational needs, stating his salary could only cover his own expenses.
- After 2005, petitioner gave support only five times until the filing of the information; thereafter he paid ₱4,000 monthly.
- Danielle Joanne Raymundo, a speech and language pathologist, confirmed BBB’s profound hearing loss and stressed the urgency of a cochlear implant and weekly one-on-one therapy to prevent permanent degradation of auditory nerves.
- AAA’s mother, DDD, corroborated that XXX’s support was sporadic (two to three instances) and that mother and grandmother shouldered most expenses.
Defense Evidence
- XXX denied deliberate deprivation, claiming AAA physically and emotionally abused him and coerced a “kasunduan” to live separately.
- He asserted he paid hospital expenses of about ₱25,