G.R. No. 255981, August 07, 2023
XXX, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner XXX was charged with violating Section 5(i) of RA 9262 (Anti-Violence Against Women and Their Children Act) for willfully depriving his wife AAA and their four children of needed love, care, protection, and financial support from November 2012 onward. The case was provisionally dismissed multiple times after the parties entered into Compromise Agreements but was revived due to alleged non-compliance. At trial, AAA testified that their separation in November 2012 due to petitioner’s infidelity led to their children stopping school for a period due to lack of financial support, forcing her into debt. She detailed petitioner’s delays in providing support and fulfilling specific promises like providing a laptop. The daughter, BBB, testified about the humiliation of having to beg for money from their father, instances of being sent away or made to wait, and petitioner’s failure to fulfill bonding and support commitments, causing them emotional and psychological torment. Petitioner denied refusing support, attributing delays to difficulties in collecting from his trucking business clients, and claimed he would double payments to compensate. He presented evidence of deposits and asserted he paid tuition, provided allowances and insurance, and had bonding moments until his children disrespected him. A former employee corroborated the collection issues and stated he never saw petitioner send his children away.

ISSUE

Whether the prosecution proved beyond reasonable doubt that petitioner violated Section 5(i) of RA 9262 by depriving his wife and children of legal support, constituting economic and psychological abuse.

RULING

The Supreme Court REVERSED the Court of Appeals and ACQUITTED petitioner. The Court held that to convict under Section 5(i) of RA 9262, the deprivation of support must be intentional or malicious. The evidence showed petitioner did not deliberately refuse support but experienced business-related delays, which he tried to offset by doubling subsequent payments. He substantially complied with his support obligations by paying tuition, providing regular monetary support, and purchasing required items, albeit sometimes delayed. The law does not penalize mere imperfections or delays in support, nor does it impose an obligation of perfect and timely provision irrespective of the husband’s actual capacity. The alleged psychological abuse stemmed from the children’s perception of neglect due to these delays and the marital infidelity, but the core legal duty of support was not maliciously withheld. The prosecution failed to prove guilt beyond reasonable doubt.