G.R. No. 232678 July 3, 2019
ESTEBAN DONATO REYES, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Esteban Donato Reyes was charged with violating Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act) for allegedly depriving his wife, AAA, of financial support. The original Information cited Section 5(e), but the Regional Trial Court (RTC), upon Reyes’s Motion to Quash, directed its amendment to Section 5(i) before arraignment, finding the alleged acts of withholding support after July 2005 better constituted a violation of that provision. The prosecution established that Reyes, married to AAA since 1969, had provided regular monthly support but unilaterally ceased doing so in July 2005. This cessation coincided with AAA learning of Reyes’s subsequent marriage to another woman and her own deteriorating health, requiring medical expenses.
Reyes admitted stopping financial support but contested the validity of his marriage to AAA, claiming a common-law relationship and forgery of the marriage certificate. He asserted he stopped support due to disappointment over a prior bigamy case AAA filed against him. The RTC convicted Reyes under Section 5(i) of R.A. 9262, a ruling affirmed by the Court of Appeals (CA) with modifications to the penalty and the addition of a fine and mandatory counseling.

ISSUE

Whether the Court of Appeals erred in affirming petitioner Esteban Donato Reyes’s conviction for violation of Section 5(i) of R.A. No. 9262 .

RULING

The Supreme Court denied the petition and affirmed the CA decision with modifications. The legal logic centered on the sufficiency of the amended Information and the proof of the crime’s elements. The amendment from Section 5(e) to Section 5(i) was merely formal, as it did not alter the factual allegations of depriving AAA of financial support; it only cited the proper penal provision. Since the amendment occurred before arraignment, it prejudiced no substantial right of the accused, who was fully informed of the charge.
On the merits, all elements of psychological violence under Section 5(i) were proven: (1) the offended party is a woman (AAA) and/or her child; (2) the woman or child has suffered psychological violence; and (3) the psychological violence is caused by acts enumerated under the law, including economic abuse. The Court found that the deliberate and unjustified withholding of financial support, which Reyes had previously regularly provided, constituted economic abuse under the law. This act caused mental anguish, emotional distress, and anxiety to AAA, especially given her medical condition and advanced age. Reyes’s defense of a void marriage was immaterial, as R.A. 9262 protects women in a dating or sexual relationship, which undisputedly existed here. His motive for stopping support was irrelevant to the fact of deprivation. The penalty was adjusted per the Indeterminate Sentence Law, and the imposed fine and counseling were affirmed as proper accessory penalties under the law.