Reyes v. People
REITERATIONFacts
The Antecedents: Petitioner Esteban Donato Reyes (Reyes) was charged with Violation of Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act) for allegedly causing mental or emotional anguish to his wife, AAA, by denying her financial support since July 2005. The Information was initially filed under Section 5(e), paragraph 2, but was later amended to Section 5(i) after Reyes filed a Motion to Quash. The prosecution presented evidence that Reyes and AAA were married on May 15, 1969, and had four children. Reyes, a pilot, stopped providing financial support in July 2005, coinciding with AAA learning that Reyes had married another woman and was living with her. AAA, suffering from various illnesses, filed the complaint due to the denial of support. Reyes claimed his marriage to AAA was invalid, that his signature was forged, and that he stopped support in July 2006 due to AAA filing a Bigamy case against him. Procedural History: The Regional Trial Court (RTC), Branch 89, Quezon City, found Reyes guilty beyond reasonable doubt of Violation of Section 5(i) of R.A. No. 9262 and sentenced him to an indeterminate penalty of three (3) years of prision correccional, as minimum, to eight (8) years and one (1) day of prision mayor, as maximum. The Court of Appeals (CA) affirmed the RTC's decision, holding that Reyes committed psychological violence by denying financial support, causing AAA emotional and mental anguish, and that the marriage was valid until annulled. The CA also noted that Reyes could be convicted under Section 5(e) if indicted for it. The Petition: Reyes filed a petition for review on certiorari before the Supreme Court, arguing that the Information was defective and should have been quashed, and that the CA erred in affirming his conviction for violating Section 5(i) of R.A. No. 9262.
Issue(s)
Whether the Information dated June 5, 2006, sufficiently stated the elements of the crime charged, specifically Violation of Section 5(i) of R.A. No. 9262. Whether petitioner Esteban Donato Reyes is guilty beyond reasonable doubt of Violation of Section 5(i) of R.A. No. 9262. Whether the RTC erred in ordering petitioner to resume giving monthly financial support to AAA.
Ruling
The Supreme Court denied the petition for review on certiorari, affirming the decision of the Court of Appeals with modifications to the penalty and the imposition of a fine and mandatory counseling.
Ratio Decidendi
On the sufficiency of the Information: The Court held that the Information dated June 5, 2006, sufficiently stated the facts necessary to constitute the crime charged under Section 5(i) of R.A. No. 9262. The Information clearly stated that AAA was the wife of Reyes, that AAA sustained mental and emotional anguish, and that such anguish was inflicted by Reyes when he deliberately and unlawfully denied her financial support. The Court emphasized that the sufficiency of an indictment is determined by whether the facts alleged, if hypothetically admitted, constitute the elements of the offense. The elements of Section 5(i) include the offended party being a woman, the relationship between the offender and the victim, the offender causing mental or emotional anguish, and such anguish being caused through acts like denial of financial support. The Court found that the Information adequately covered these elements, thus satisfying the requirements of Section 6, Rule 110 of the Rules of Court. On the guilt of petitioner for Violation of Section 5(i) of R.A. No. 9262: The Court affirmed the finding of guilt, holding that the prosecution adequately proved all the elements of the crime. The existence of a valid marriage between Reyes and AAA was established by a certified copy of their marriage certificate, which is accorded full faith and credence as a public document. The Court reiterated that a marriage is deemed valid until declared otherwise in a judicial proceeding, obligating Reyes to support AAA. Furthermore, even if the marriage were void ab initio, Reyes could still be held liable under R.A. No. 9262, as the law covers violence against women perpetrated by individuals with whom the victim had a sexual or dating relationship or a common child. The Court found that Reyes' denial of financial support, which began in July 2005, caused AAA mental and emotional suffering, adversely affecting her health. Reyes' excuse that he stopped support because AAA filed a Bigamy case against him was deemed unacceptable, as the denial of support was seen as an attempt to control AAA's conduct and pressure her to withdraw the case. On the order to resume financial support: The Court agreed with the CA that Reyes should comply with the Temporary Protection Order (TPO) directing him to resume monthly financial support. The Court noted that Reyes failed to present any evidence to show that he is no longer employed, has no gainful employment, or lacks the means to provide support. Therefore, the directive to resume financial support was upheld.
Main Doctrine
The denial of financial support to a woman, causing her mental or emotional anguish, constitutes psychological violence under Section 5(i) of R.A. No. 9262, even if the offender claims the marriage is void, as long as a marriage certificate exists and has not been judicially annulled, and the offender has had children with the victim.