G.R. No. 239215 . July 12, 2022
RANDY MICHAEL KNUTSON, ACTING ON BEHALF OF MINOR RHUBY SIBAL KNUTSON, PETITIONER, VS. HON. ELISA R. SARMIENTO-FLORES, IN HER CAPACITY AS ACTING PRESIDING JUDGE OF BRANCH 69, REGIONAL TRIAL COURT, TAGUIG CITY, AND ROSALINA SIBAL KNUTSON, RESPONDENTS.

FACTS

This case originated from a Petition for the Issuance of a Permanent Protection Order (PPO) filed by Randy Michael Knutson on behalf of his minor daughter, Rhuby, against her mother, Rosalina Sibal Knutson, under Republic Act No. 9262 , or the Anti-Violence Against Women and Their Children Act of 2004. The petitioner alleged that the respondent mother had committed acts of psychological violence and emotional abuse against the child. The Regional Trial Court denied the petition, ruling that a protection order under RA 9262 could not be issued against a woman, as the law designates women as the protected class and not as potential perpetrators. The case was elevated to the Supreme Court to resolve this legal interpretation.

ISSUE

The core legal issue is whether a protection order under Republic Act No. 9262 can be issued against a woman, specifically a mother, for alleged acts of violence committed against her own child.

RULING

In his Concurring Opinion, Justice Leonen affirmed that a protection order under RA 9262 can be issued against a woman, including a mother, who commits violence against her child. The legal logic proceeds from a fundamental reinterpretation of the law’s underlying philosophy. While RA 9262 was enacted to address the historical and societal context of patriarchy and gender-based violence where women are most often victims, its primary objective is the protection of human dignity and safety from abuse within intimate relationships, irrespective of the perpetrator’s gender. The Constitution mandates the State to ensure the fundamental equality of women and men, which implies actively dismantling stereotypes, not reinforcing them by perpetually casting women solely as incapable victims.
Labeling women exclusively as victims and men exclusively as perpetrators entrenches the very heteronormative and patriarchal stereotypes the law seeks to overcome. Violence is ultimately an issue of power and control, not merely gender. To hold that women are legally immune from being respondents under RA 9262 would create an absurd and dangerous situation where a child suffering abuse from a mother is denied the law’s protective mechanisms. The law’s definition of “violence against women and their children” and the reliefs it provides are designed to safeguard the vulnerable party in a domestic context—the child in this instance. Therefore, a rigid, gender-exclusive interpretation that bars a child from seeking protection from maternal abuse contravenes the law’s paramount intent to protect human rights and ensure safety within the family. The Court’s ruling correctly allows the law to be applied to hold any individual accountable for perpetrating violence, thereby fulfilling its protective purpose.