G.R. No. L-1878 - People vs Navarro

Case Summary (G.R. No. L-1878)

Key Dates and Procedural Milestones

Birth of child: April 11, 2006.
Amended Information filed: August 25, 2011 (charging acts from April 11, 2006 up to present).
RTC Orders: June 27, 2018 (Order granting demurrer and acquitting accused but awarding civil support); October 18, 2018 (denial of reconsideration).
CA Decision: February 24, 2021 (reversed award of civil liability and remanded for accounting/evidence to determine actual support); CA Resolution denying reconsideration: February 28, 2022.
Supreme Court Decision on petition: November 13, 2023.

Charge and Legal Elements Alleged

The Amended Information charged violation of Section 5(i) of RA 9262 for psychological and economic abuse by “deliberately failing, refusing, denying and depriving” the complainant and their minor child of financial support despite the accused’s being gainfully employed, with intent to cause mental or emotional anguish, public ridicule or humiliation. The prosecution thus needed to establish (a) deliberate intent to willfully refuse or consciously deny financial support to the minor child, and (b) mental or emotional anguish caused to the woman and/or child.

Trial Proceedings and Evidence Presented

The accused pleaded not guilty and trial proceeded after pre-trial. The prosecution presented the private complainant (AAA260504) and another witness (CCC260504). AAA260504 testified regarding the relationship, paternity of the child (born April 11, 2006), and allegations of non-provision of child support despite demand. The record indicates that while non-provision was undisputed, the prosecution failed to prove the requisite elements of Section 5(i) beyond reasonable doubt: specifically the deliberate intent element and the mental/emotional anguish element were not adequately established by testimony.

RTC Ruling: Demurrer Granted; Acquittal; Civil Support Award

With leave of court, the accused filed a Motion for Leave to File Demurrer to Evidence. The RTC granted the demurrer and acquitted the accused for lack of proof of the crime. However, the RTC nonetheless ordered the accused to pay USD 100.00 per month (or peso equivalent) to the minor child from April 2006 to June 2018. The RTC explained that an acquittal based on reasonable doubt does not necessarily absolve the accused of civil liability, which may be proven by a preponderance of evidence; hence it declared civil liability for support.

Legal Effect of a Demurrer to Evidence and Due Process Considerations

The Rules of Court provide that when a demurrer to evidence is filed without leave, the accused waives his right to present evidence and submits the case for judgment on the prosecution’s evidence; however, when leave is granted, the accused preserves the right to adduce evidence on both the criminal and civil aspects if the demurrer is denied, and that right is not lost when the demurrer is granted. Jurisprudence cited in the record (e.g., Salazar v. People; Cacdac v. Mercado) establishes that if a demurrer is granted and the accused is acquitted, the proper procedure is to render a partial judgment granting the demurrer and then continue the trial on the civil aspect so the accused may present evidence on the civil claims. The Supreme Court found that the RTC’s immediate award of support without allowing the accused the opportunity to present evidence on financial capacity violated the accused’s constitutional right to due process.

Court of Appeals Ruling and Basis for Remand

The Court of Appeals agreed that the trial court erred in fixing the amount of support without record evidence concerning the means of the giver or the needs of the recipient. The CA reversed and set aside the RTC orders insofar as civil liability was concerned and remanded the case to the RTC “for proper accounting, reception of evidence, and evaluation thereof to determine the actual amount of the accused-appellant’s liability for support, if any.”

Issue Presented to the Supreme Court

The Supreme Court addressed whether the CA erred in affirming the civil liability for support in favor of the minor child and whether the award of civil liability ex delicto was proper given the RTC’s acquittal of the accused for the criminal offense.

Supreme Court Analysis on Acquittal, Civil Liability ex delicto, and Jurisprudential Basis

The Court reiterated established principles: (1) an acquittal based on reasonable doubt does not extinguish a civil liability arising from the same act or omission because the civil cause requires only preponderance of evidence; (2) the civil action for recovery of liability arising from the offense is deemed instituted with the criminal action under Rule 111, section 1 of the Revised Rules on Criminal Procedure; and (3) judgments must state whether an acquittal was due to reasonable doubt or a finding that the act did not occur. The Court observed that the RTC and CA uniformly found that the acquittal was based on reasonable doubt. Given that filiation was admitted and established (and that mere failure to provide financial support ordinarily entails civil, not criminal, liability), the courts properly concluded that the accused remained civilly liable in principle. The Court relied on statutory and jurisprudential authority (including Article 29 of the Civil Code, the Family Code’s provisions on parental support, and prior cases such as Manantan and others cited in the record) to support the proposition that civil liability may survive an acquit

Case Syllabus (G.R. No. L-1878)

Case Caption and Court Information

Reporter citation: 949 Phil. 221; SECOND DIVISION; G.R. No. 260504 (Formerly UDK 17607), November 13, 2023.
Parties: XXX260504 (Petitioner/Accused) v. AAA260504 (Private offended party/Respondent). An asterisk in the caption indicates confidentiality measures applied to the private offended parties per Amended Administrative Circular No. 83-2015 and related privacy protections.
Supreme Court ponente: Justice M. Lopez, J. Leonen, SAJ. (Chairperson), Lazaro‑Javier, and Kho, Jr., JJ., concurred.
Case documents: Petition for Review on Certiorari (Rollo, pp. 4–26); appealed Court of Appeals Decision (Rollo, pp. 62–68) and Resolution (Rollo, pp. 31–33); RTC Orders (Rollo, pp. 69–75; 76–78).

Underlying Charge and Statute Allegedly Violated

Statutory basis: Violation of Section 5(i) of Republic Act No. 9262 (Anti‑Violence Against Women and Their Children Act of 2004).
Accusatory portion (as alleged in the Amended Information dated August 25, 2011): From April 11, 2006 up to the present, in the xxxxxxxxxxxxxxxxx, Philippines, XXX260504, then the boyfriend of AAA260504, with intent to cause mental or emotional anguish, public ridicule or humiliation, willfully, unlawfully and feloniously caused psychological abuse and economic abuse against AAA260504 by deliberately failing, refusing, denying and depriving AAA260504 and their minor child BBB260504 financial support despite being gainfully employed; contrary to law. (Rollo, p. 88.)

Factual Allegations and Testimony

Relationship and filiation: AAA260504 and XXX260504 had a romantic relationship which produced a child, BBB260504, born on April 11, 2006; paternity/filiation was established in the records and XXX260504 admitted paternity. (Rollo, pp. 70; 65.)
Core allegation: Despite demand, XXX260504 allegedly failed to render child support to BBB260504.
Prosecution witnesses: The prosecution presented AAA260504 and CCC260504 to prove the guilt of XXX260504. (Rollo, pp. 70, 104.)
Evidentiary outcome at trial: The testimonies of the prosecution’s witnesses did not substantiate the elements of Section 5(i) as required for criminal conviction; while non‑provision of support was undisputed, the prosecution failed to prove deliberate intent to refuse support and the required mental/emotional anguish elements. (Rollo, pp. 70–73; 65.)

Pre‑Trial, Demurrer to Evidence, and Procedural Posture at RTC

Plea and trial: On arraignment, XXX260504 pleaded not guilty; pre‑trial conference terminated and trial on the merits proceeded. (Rollo, p. 63.)
Demurrer to Evidence: After the prosecution rested, with prior leave of court, XXX260504 filed a Motion for Leave to File Demurrer to Evidence (Rollo, pp. 92–99).
- Grounds articulated in the demurrer: (1) There was no deliberate denial of financial support by the accused; rather, AAA260504 had refused offered support because the amount was insufficient. (2) Psychological abuse/violence was not adequately proven; AAA260504 did not testify to social humiliation, wounded feelings, or anxiety resulting from the alleged conduct. (Rollo, pp. 95; 92–99.)
RTC disposition on demurrer: The RTC granted the demurrer to evidence, thereby acquitting XXX260504 of the crime charged, but in the same Order found him civilly liable to pay USD 100.00 per month (or peso equivalent) to minor BBB260504 from April 2006 to June 2018. The RTC’s rationale: acquittal based on reasonable doubt does not absolve civil liability which is proved by preponderance of evidence. (RTC Order, June 27, 2018; Rollo, pp. 69–75; 74–75.)

RTC Orders and Post‑Decision Motions

RTC dispositive language on acquittal and support: “Demurrer to Evidence is GRANTED. Consequently, accused is ACQUITTED of the crime charged. However, he is hereby ordered to pay the sum of US$100.00 per month or its peso equivalent, to the minor [BBB260504] from April 2006 to June 2018.” (Rollo, pp. 74–75.)
Motion for Partial Reconsideration by XXX260504: Argued (a) civil liability ex delicto in the dispositive portion is incongruent with the acquittal in the body of the Order; (b) award of support lacked evidentiary foundation required by preponderance of evidence; (c) due process violation because no opportunity to prove financial capacity; and (d) if liability exists it should be from other legal sources, not ex delicto. (Rollo, pp. 100–110; 101–107.)
RTC denial of reconsideration: RTC reiterated its view that acquittal on reasonable doubt does not exonerate obligation to support under Article 195 of the Family Code. (RTC Order, Oct. 18, 2018; Rollo, pp. 76–78.)

Appeal to the Court of Appeals (CA)

Appeal filed by XXX260504 to CA (brief and arguments): Claimed reversible error in (1) fixing amount of support without due notice and hearing, and (2) awarding civil liability ex delicto in the dispositive portion despite stating no crime was committed in the body of the Order. (Rollo, pp. 125–145; 128–129.)
CA ruling (Decision, Feb. 24, 2021): Granted the appeal in so far as the award of civil liability is concerned. The CA found no evidence showing the means of the giver or the needs of the recipient minor child and remanded the case to the RTC “for proper accounting, reception of evidence, and evaluation thereof to determine the actual amount of the accused‑appellant’s liability for support, if any.” (Rollo, pp. 62–68; dispositive at p. 67.)
Motions for Reconsideration at CA: Both parties moved for reconsideration; CA denied both motions (Resolution, Feb. 28, 2022), finding them utterly devoid of merit. (Rollo, pp. 34–42; 53–58; 31–33.)

Issues Presented to the Supreme Court

Principal issue for the Supreme Court: Whether the Court of Appeals erred in affirming XXX260504’s civil liability for support in favor of BBB260504 and in remanding the case to the RTC for determination of the actual amount of support. (Rollo, p. 10; statement of sole issue.)
Main contentions of XXX260504 on petition: (1) CA erred in affirming civil liability ex delicto while the accused was categorically found not to have committed the acts in the Information; (2) the courts erred in applying RA 9262. (Rollo, p. 10.)
AAA260504’s Comment to the petition: Sought denial of the petition and argued (1) the court a quo did not err in awarding civil liability ex delicto, and (2) the assigned errors were factual in nature beyond the scope of a Rule 45 petition. (Rollo, pp. 182–188.)

Governing Legal Principles and Procedural Rules Cited by the Court

Scope of Supreme Court review: Rule 45 petitions generally raise questions of law; the Court does not re‑weigh evidence unless there is clear arbitrariness, capriciousness, or palpable error. The factual findings of the courts a quo are final when supported by su