G.R. Nos. 77737-38, August 15, 1988
CHRISTINA MARIE DEMPSEY, ET AL. vs. REGIONAL TRIAL COURT, ET AL.

FACTS

Two criminal informations were filed against Joel Dempsey before the Municipal Trial Court (MTC) of Olongapo City for violating Presidential Decree No. 603 (The Child and Youth Welfare Code). The charges alleged he willfully abandoned his minor child, Christina Marie Dempsey, and failed to provide adequate support despite capacity to do so. Dempsey, after arraignment, voluntarily pleaded guilty to both charges. The MTC convicted him, imposing imprisonment, fines, and civil liabilities including monthly child support, recognition of the child as natural, exemplary damages, and attorney’s fees.
Dempsey appealed to the Regional Trial Court (RTC), which reversed the MTC decision. The RTC ruled that parental obligations under P.D. 603 pertained only to legitimate or adopted children, not an acknowledged illegitimate child like Christina. It further held that criminal liability for failure to support does not exist and that the MTC acted outside its competence, suggesting jurisdiction lay with the Department of Social Services and Development (DSSD). The petitioners, the minor child and the People, elevated the case to the Supreme Court.

ISSUE

Whether the Regional Trial Court erred in reversing the Municipal Trial Court’s conviction based on the accused’s plea of guilty and in holding that the MTC lacked jurisdiction.

RULING

The Supreme Court granted the petition, reversing the RTC decision. The Court found the RTC committed reversible error. First, it failed to consider that the MTC’s conviction was squarely based on Dempsey’s valid and unchallenged plea of guilty to the charges under P.D. 603. The law’s provisions on parental duties and criminal sanctions for abandonment and non-support apply to all parents, irrespective of the child’s legitimacy status. The RTC erroneously applied Article 161 of P.D. 603, which deals with reporting abandoned children to the DSSD. The child was not “abandoned” as legally defined—being cared for by her mother—thus, the DSSD had no jurisdiction over the criminal aspect. The MTC properly exercised its jurisdiction.
However, the Supreme Court modified the MTC judgment. It corrected the MTC’s error in ordering the recognition of the child as part of the civil liability in the criminal case, as recognition is a matter governed by civil law, not properly litigated in this criminal proceeding. The Court also found the penalties imposed required modification and that the awards for exemplary damages and attorney’s fees were improper absent aggravating circumstances. Consequently, the MTC decision was reinstated with modifications: for Criminal Case No. 68-86 (abandonment), Dempsey was sentenced to one month imprisonment and a P300 fine; for Criminal Case No. 69-86 (non-support), he was acquitted.