Xxx v. People
REITERATIONFacts
The Antecedents: AAA and XXX were married on March 8, 2005, after AAA became pregnant. They lived with XXX's family, where AAA allegedly did not receive proper medical care. An argument ensued, and AAA left the family home two months after marriage. Their son, BBB, was born on August 2, 2005, diagnosed with Congenital Torch Syndrome, leading to delayed development and hearing impairment. AAA incurred significant expenses for BBB's medical needs, including a hearing aid and therapy. XXX initially claimed inability to provide financial support, stating his salary only covered his expenses. He later told AAA to leave him alone and that he was happy with his new family. AAA also sought financial help from XXX's new partner and parents, but to no avail. BBB was enrolled in a school for the hearing impaired, with AAA shouldering the tuition. XXX proposed a school for children with different disabilities, which AAA found less suitable for BBB's specific needs. AAA also informed XXX about a potential P1,000,000.00 per ear procedure for BBB, but XXX consistently stated he had insufficient funds. Prior to the filing of the case, XXX only provided child support five times. After a resolution recommending an information was issued, XXX began providing P4,000.00 monthly support. A speech and language pathologist testified on BBB's auditory, speech, and language delays and recommended a hearing device or cochlear implant and therapy. AAA's mother corroborated AAA's testimony regarding XXX's limited support. XXX denied the charges, claiming AAA subjected him to physical and emotional abuse, pressured him to stop schooling, belittled his job, and made him sleep on the floor. He claimed he paid for BBB's hospital expenses and last saw his child in Christmas 2005. He asserted he was forced to sign a separation agreement and only learned of BBB's condition in 2008, after which he provided support ranging from P1,500.00 to P2,000.00 monthly between August and December 2008. He explained his statement about a new family was to stop AAA from bothering him. He admitted failing to provide support from December 2005 to August 2008 due to anger at AAA and her request for a large sum he could not afford. He presented receipts for support given between 2010 and 2013. He offered P6,000.00 for BBB's support when about to post bail, which AAA questioned. He admitted his family contributed P100,000.00 towards BBB's operation, raised through AAA's charity efforts and ticket sales. At the time of trial, he earned P16,000.00 monthly, P5,000.00 of which he intended for BBB's support. Procedural History: The Regional Trial Court (RTC) of ██████████ City, Branch 199, found XXX guilty beyond reasonable doubt of violating Section 5(e)(2) of RA 9262. He was sentenced to six (6) months and one (1) day of prision correccional, a fine of P100,000.00, and ordered to pay P10,000.00 as moral damages, and to undergo mandatory psychological counseling. The RTC found that XXX deliberately deprived AAA and BBB of sufficient financial support for BBB's medical and educational needs, disbelieved XXX's claims of abuse by AAA, and found his assertion of being forced to sign a kasunduan unsubstantiated. The Court of Appeals (CA) affirmed the RTC's decision. The Petition: XXX filed a Petition for Review on Certiorari before the Supreme Court, assailing the CA's decision. He argued that he had documented support payments from 2010 to 2013, shouldered BBB's birth hospitalization expenses, and denied deliberately depriving BBB of financial support. He claimed limited income at BBB's birth, AAA's manipulation, and that his failure to provide support was not malicious.
Issue(s)
Whether the petitioner committed a violation of Section 5(e)(2) of Republic Act No. 9262 by depriving his child of sufficient financial support. Whether the petitioner's claims of AAA's manipulation, alleged abuse, and lack of malice warrant his acquittal.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, upholding the conviction of XXX for violation of Section 5(e)(2) of Republic Act No. 9262. The dispositive portion of the Supreme Court's decision is: "WHEREFORE, the instant petition is DENIED. The assailed November 3, 2015 Decision of the Court of Appeals in CA-G.R. CR No. 36620 finding petitioner XXX GUILTY beyond reasonable doubt of violating Section 5(e)(2) of Republic Act No. 9262 otherwise known as the Anti-Violence Against Women and Their Children Act of 2004 is hereby AFFIRMED in toto. Petitioner is sentenced to suffer the straight penalty of six (6) months and one (1) day of prision correccional, and to pay a fine of One Hundred Thousand Pesos (P100,000.00) and moral damages of Ten Thousand Pesos (P10,000.00). He is also directed to undergo mandatory psychological counseling and to report compliance to the trial court."
Ratio Decidendi
On the issue of violation of Section 5(e)(2) of RA 9262: The Court found that all elements of the violation were present. It was established that XXX and AAA were married, XXX acknowledged BBB as his child, and XXX failed to provide sufficient support for BBB. The Court noted that XXX withheld financial support due to anger towards his wife and only began providing support after the complaint was filed. The obligation to support a child, as defined in Article 194 of the Family Code, includes sustenance, dwelling, clothing, medical attendance, education, and transportation, proportionate to the child's needs and the parent's capacity. The Court found XXX's support of approximately P10,000.00 over five years insufficient for BBB's needs, especially considering his congenital condition. The Court emphasized that BBB's best interest must prevail over marital conflicts, and XXX's anger towards his wife did not justify terminating support for their child. The Court also highlighted that XXX's claims of AAA preventing him from giving support and forcing him to sign a separation agreement remained unsubstantiated, as no evidence was presented to support these assertions. On the issue of petitioner's claims of manipulation, abuse, and lack of malice: The Court dismissed XXX's arguments regarding AAA's alleged manipulation and his own lack of malice. The Court reiterated that a petition for review on certiorari is limited to questions of law, and XXX's claims involved questions of fact that had already been passed upon by the lower courts. The findings of fact of the RTC, affirmed by the CA, are accorded high respect. Furthermore, the Court clarified that RA 9262, being a special law, penalizes acts that are mala prohibita, meaning malice or intent is immaterial. The sole inquiry is whether the act of deprivation of financial support was committed. XXX's argument of absence of malice was therefore irrelevant to the determination of his guilt.
Main Doctrine
The deprivation of financial support to a child, as defined under Section 5(e)(2) of RA 9262, is a continuing offense and constitutes economic abuse. The best interest of the child must prevail over marital conflicts, and the absence of malice is immaterial as the offense is malum prohibitum.