G.R. No. 252087 , February 10, 2021
XXX, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner XXX was charged with violating Section 5(i) of R.A. 9262 (Anti-Violence against Women and Children Act of 2004) for willfully depriving his minor child CCC of financial support, causing mental and emotional anguish to his wife AAA. The prosecution presented AAA and her sister BBB. AAA testified that she and petitioner lived together since 1997, married in 2001, and had a child, CCC, in 2000. AAA had no income and was dependent on petitioner or BBB. Petitioner, a mechanic, provided P1,000 to P2,000 monthly until 2005 when he stopped coming home and providing support. A barangay conciliation in 2005 resulted in an agreement for petitioner to provide P4,000 monthly, but he only gave P1,000 once. AAA filed the criminal complaint in 2016 as her sister BBB, who had been supporting them, became too sick to continue. BBB testified that she financially supported AAA and CCC, including paying for CCC’s private school education, and observed AAA was always crying after petitioner left.
The defense presented petitioner, who testified he left AAA in 2005 due to her violent and harassing behavior. He claimed he provided financial support when he could, including P15,000 for a sibling’s death, P3,000 for false teeth, and for CCC’s tuition in 2006. He offered P1,000 to P2,000 monthly support during barangay proceedings, conditioned on CCC attending public school, but AAA refused. He worked as a mechanic until 2010, was diagnosed with hypertensive cardiovascular disease in 2011, and is currently unemployed, supported by his family. A counseling psychologist testified petitioner showed symptoms of Post-Traumatic Stress Disorder due to negative experiences with AAA, affecting his motivation to work but not his moral reasoning or understanding of his obligation to support his daughter.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s decision finding petitioner guilty beyond reasonable doubt of violating Section 5(i) of R.A. 9262 for deprivation of financial support causing mental or emotional anguish.

RULING

The Supreme Court granted the petition, reversed the Court of Appeals’ decision, and acquitted petitioner. The Court held that the prosecution failed to prove the elements of the crime under Section 5(i) of R.A. 9262. Specifically, it failed to establish that the mental or emotional anguish was caused through the denial of financial support. The evidence showed that AAA’s anguish primarily stemmed from petitioner’s abandonment of their conjugal dwelling and their strained relationship, not solely from the deprivation of financial support. The Court distinguished between a mere failure or inability to provide support, which is not criminalized under the provision, and a deliberate, malicious, or unjust refusal to provide support intended to cause psychological suffering. The prosecution did not prove that petitioner’s cessation of support was malicious or unjust, especially considering evidence of his subsequent unemployment and health condition. The elements of the crime were not proven beyond reasonable doubt.