Case Summary (G.R. No. 254186)
Procedural History
The proceedings began with an Amended Information filed on August 25, 2011, charging XXX260504 with violating Section 5(i) of Republic Act No. 9262, which pertains to psychological and economic abuse. After a trial, the RTC acquitted XXX260504 due to insufficient evidence establishing guilt beyond a reasonable doubt, yet still ordered him to provide child support of USD 100.00 per month or its equivalent in pesos for the specified period.
RTC's Determination
The RTC emphasized that while XXX260504 was acquitted based on reasonable doubt regarding the criminal charges, this did not absolve him of civil liability, which could be established by a preponderance of evidence. The court categorized the support obligation as separate from the criminal offense, justifying the obligation despite the acquittal.
Appeal to the Court of Appeals
Dissatisfied with the RTC's decision, XXX260504 filed a Motion for Partial Reconsideration, arguing that the civil liability award was incongruous with his acquittal, lacked evidentiary support, and violated due process rights as he was not given an opportunity to demonstrate his financial capacity. The RTC denied this Motion, reinforcing its previous conclusions.
Court of Appeals' Review
Upon appeal, the Court of Appeals (CA) found merit in XXX260504's assertions regarding the award of civil liability, ruling that no evidence was provided to demonstrate the financial means of the obligor relative to the needs of the minor child. Consequently, the CA remanded the case back to the RTC for proper accounting and further evidentiary hearing to determine the actual amount of support owed.
Subsequent Motions for Reconsideration
Both parties filed separate Motions for Reconsideration following the CA's Decision, but the CA denied these motions, asserting they lacked merit and reaffirmed its prior ruling to remand.
Rationale for Jurisdiction and Civil Liability
The main question before the Supreme Court was whether the CA erred in affirming XXX260504's civil liability for support despite his acquittal of the criminal charges. The Court clarified the intersection between criminal liability and civil obligations, reinforcing that acquittal on the basis of reasonable doubt does not preclude civil liability arising from the same circumstances as the criminal charge.
The Court's Conclusion
The Supreme Court articulated that civil liabilities can exist independently of
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Background and Procedural History
- The case involves XXX260504 as petitioner and AAA260504 as respondent.
- Originated from an Amended Information dated August 25, 2011, charging XXX260504 with violation of Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004).
- Accusation centered on deliberate refusal and denial of financial support and causing psychological and economic abuse to AAA260504 and their minor child BBB260504.
- XXX260504 pleaded not guilty and trial on the merits proceeded after pre-trial.
- Prosecution presented testimonies including from AAA260504 and CCC260504.
- Testimonies showed failure/refusal to provide support, but evidence did not conclusively prove deliberate denial or psychological abuse.
- XXX260504 filed a Motion for Leave to file Demurrer to Evidence, citing insufficient proof of deliberate refusal and psychological abuse.
Ruling of the Regional Trial Court (RTC)
- The RTC granted the Demurrer to Evidence and acquitted XXX260504 of the criminal charge due to reasonable doubt.
- Despite acquittal, RTC found XXX260504 civilly liable to pay USD 100/month or peso equivalent in support of minor child from April 2006 to June 2018.
- The RTC emphasized that acquittal on criminal charge did not absolve civil liability, which requires only preponderance of evidence.
- Motion for Partial Reconsideration by XXX260504 was denied by the RTC.
Court of Appeals (CA) Decision and Resolution
- XXX260504 appealed, arguing errors: fixing support without due notice/hearing and awarding civil liability ex delicto despite acquittal.
- CA reversed and set aside RTC's award of civil liability; no evidence showed accused's means or child's needs.
- Remanded the case to RTC for proper accounting and to determine actual amount of support.
- Motions for Reconsideration by both parties were denied by CA for lack of merit.
Issues Presented to the Supreme Court
- Whether the CA erred in affirming civil liability of XXX260504 for the support of