Republic Act No. 9262 allows a father to apply for protection and custody orders on behalf of his minor child against the child's mother who has allegedly committed acts of violence against the child; the mother can be considered an offender under the Act in such circumstances.

Randy Michael Knutson, an American citizen, and Rosalina Sibal Knutson, a Filipina, married and had a daughter, Rhuby. After their estrangement due to Rosalina's alleged extra-marital affairs, gambling addiction, and neglect of Rhuby, Randy claimed Rosalina also maltreated Rhuby physically and psychologically, including threatening to kill her. These events led Randy to seek legal protection for Rhuby.

• Randy Michael Knutson (Randy) and Rosalina Sibal Knutson (Rosalina) were married and had a daughter, Rhuby Sibal Knutson.
• The family lived in the Philippines in 2011, but Randy and Rosalina became estranged after Randy discovered Rosalina's extra-marital affairs.
• Randy alleged that Rosalina became addicted to casinos, spent weeks in gambling dens leaving Rhuby with strangers, and incurred large debts, leading her to sell family properties.
• Rosalina allegedly rented an apartment, got a boyfriend, and was advised by Randy to be discreet.
• Randy discovered Rosalina maltreated her own mother in Rhuby's presence.
• Rosalina allegedly hurt Rhuby by pulling her hair, slapping her face, knocking her head, and once pointed a knife at Rhuby threatening to kill her.
• Rosalina texted Randy about her plan to kill their daughter and commit suicide. Randy reported this to the police, who stated they could not assist in domestic issues.
• Rosalina sent Randy naked pictures with a message that he would not see that body again.
• Neighbors complained about noisy parties and pot sessions in Rosalina's apartment, and her lease was terminated after marijuana plants were confiscated.
• On December 7, 2017, Randy, on behalf of minor Rhuby, filed a petition under RA 9262 for Temporary and Permanent Protection Orders against Rosalina, alleging she placed Rhuby in a harmful environment.

• Randy Knutson argued that RA 9262 allows a father to apply for protection and custody orders on behalf of his minor child who is a victim of violence by the child's mother.
• He contended that the term "any person" in RA 9262, referring to the offender, is not limited to male offenders and can include the mother.
• He asserted that RA 9262 should be liberally construed to promote the protection and safety of victims of violence, including children abused by their mothers.
• He maintained that the legislative intent of RA 9262 is to provide all possible protection to children.

• Hon. Elisa R. Sarmiento-Flores (RTC Judge) argued that protection and custody orders under RA 9262 cannot be issued against a mother who allegedly abused her own child, as the child's mother is not included as an offender under the law's definition.
• The RTC reasoned that the offended party under RA 9262 may be the wife, former wife, a woman in a sexual/dating relationship, or with whom the man has a common child, or HER child; the mother is specifically mentioned as an offended party, not an offender in relation to her child.
• The RTC stated that remedies under RA 9262 are not available to the father because he is not a "woman victim of violence."
• Citing Ocampo v. Arcaya-Chua, the RTC asserted that a protection order cannot be issued in favor of a husband against his wife.
• The RTC contended that the word "children" in the title of RA 9262 ("Anti-Violence Against Women And Their Children Act") should not be isolated from "women" due to the conjunction "and," meaning the children protected are those under the care of the woman victim of violence.
• The RTC argued that while Rosalina may have neglected, abandoned, or abused Rhuby, other laws and rules, not RA 9262, are available for the child's protection.

• Whether the father can avail of remedies under RA No. 9262 on behalf of his minor child against the mother's alleged violent and abusive acts.
• Whether a mother who allegedly committed violent and abusive acts against her own child can be considered an "offender" under RA No. 9262.

• Yes, the father can avail of remedies under RA No. 9262 on behalf of his minor child against the mother, and the mother can be considered an offender under the Act.
• Section 9(b) of RA 9262 explicitly allows "parents or guardians of the offended party" to file a petition for protection orders. The law uses the word "parents" without qualification, thus including the father.
• The Rules of Court, applicable suppletorily, allow a minor to sue with the assistance of their father. Randy filed the petition on behalf of Rhuby, the minor child victim.
• The Ocampo case is inapplicable as Randy is not seeking a protection order for himself but for his minor daughter Rhuby. The RTC should have examined the evidence for the child's best interest.
• RA 9262 defines "violence against women and their children" as acts committed by "any person." The Court in Garcia v. Drilon held that "person" is gender-neutral and can include female offenders, such as in lesbian relationships or through conspiracy.
• The fact that a social legislation affords special protection to a particular sector (women and children) does not exclude its members from violating such law. Mothers can be offenders under RA 9262.
• International instruments like the Convention on the Rights of the Child, to which the Philippines is a party, mandate protection of children from all forms of violence, including from parents.
• The penal provisions under Section 5 of RA 9262 use the disjunctive "or" (e.g., "woman or her child"), indicating that the child can be a victim independently of the mother.
• A restrictive interpretation frustrates the policy of RA 9262 to afford special attention to women and children as victims of violence and abuse.
• The petition for certiorari was granted, the RTC orders were set aside, and a Permanent Protection Order was ordered to be issued immediately.

• Hierarchy of Courts — This doctrine requires that legal remedies be sought in lower courts before resorting to higher courts. The Supreme Court acknowledged this doctrine but found exceptions applicable, such as the case being one of first impression, involving transcendental importance, public welfare, and raising a pure question of law, justifying direct recourse.
• Absolute Sentencia Expositore Non Indiget — When the language of the law is clear, no explanation or interpretation is required. The Court applied this to Section 9(b) of RA 9262, stating that "parents" clearly includes the father.
• Ubi lex non distinguit, nec nos distinguere debemus — When the law does not distinguish, courts should not distinguish. The Court used this to argue that since RA 9262 does not distinguish which parent can file for a protection order for a child, the father is not excluded.
• Liberal Construction of Statutes — Statutes, particularly remedial ones or those designed for protection, should be interpreted generously to achieve their purpose. RA 9262, under its Section 4, mandates liberal construction to promote the protection and safety of victims. The Court applied this to allow the father to seek remedies and to include the mother as a potential offender to protect the child.
• Statutory Construction (Legislative Intent) — The primary goal in interpreting a statute is to ascertain and give effect to the legislature's intent. The Court found that the RTC's restrictive interpretation would frustrate the legislative intent of RA 9262 to protect children from violence, even if perpetrated by their mother.
• Best Interest of the Child — In all actions concerning children, their best interest shall be the primordial and paramount consideration. The Court emphasized that the RTC should have focused on Rhuby's best interest rather than dismissing the case on procedural grounds.
• Principle of Conspiracy (under Revised Penal Code) — This principle allows persons not directly committing the crime to be held liable if they acted in concert with the main perpetrator. The Court, referencing Go-Tan v. Spouses Tan, noted that this principle can apply to RA 9262, expanding the scope of "offender" beyond the intimate partner if conspiracy is shown (though not the primary basis for the mother being an offender in this specific case, it was mentioned in the context of "any person").

• "The judicial quest to discern who may be offenders as defined in a penal statute is at times abstruse in itself."
• "The law speaks in clear language and no explanation is required. There is no occasion for the Court to interpret but only to apply the law when it is not ambiguous."
• "When the law does not distinguish, the courts must not distinguish."
• "The fact that a social legislation affords special protection to a particular sector does not automatically suggest that its members are excluded from violating such law."
• "Any violence is reprehensible and harmful to the child's dignity and development."
• "The Court refuses to be an instrument of injustice and public mischief perpetrated against vulnerable sectors of the society such as children victims of violence. The Court will not shirk its bounden duty to interpret the law in keeping with the cardinal principle that in enacting a statute, the legislature intended right and justice to prevail."

• Garcia v. Drilon — Cited to support that RA 9262 does not exclude men as victims entirely (though primarily protects women and children), and more importantly, that the term "person" as an offender is gender-neutral, encompassing lesbian relationships and potentially other individuals through conspiracy. It upheld the constitutionality of RA 9262. The current case reiterated that "person" as an offender can include women.
• Ocampo v. Arcaya-Chua — Cited by the RTC to argue that a protection order cannot be issued in favor of a husband against his wife. The Supreme Court distinguished this, stating that Randy Knutson was not seeking an order for himself but for his minor daughter, Rhuby. The SC noted that even in Ocampo, the protection order for the minor daughter was found justified.
• Go-Tan v. Spouses Tan — Cited to illustrate that offenders under RA 9262 are not strictly limited to the intimate partner, as parents-in-law were held as proper respondents due to conspiracy with the husband in tormenting the wife. This supports the broader interpretation of "any person" as an offender.

• Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004) — The entire case revolves around the interpretation and application of this Act.
• RA 9262, Section 3(a) (Definition of Violence Against Women and Their Children) — Defines VAWC and identifies the offender as "any person" and the victim as a woman or "her child." Crucial for determining who can be an offender and a victim.
• RA 9262, Section 3(h) (Definition of Children) — Defines children as those below 18 or older but incapable of self-care, including "biological children of the victim and other children under her care." Used by the RTC to argue children are linked to the woman victim.
• RA 9262, Section 4 (Construction) — Mandates liberal construction of the Act. Invoked by the petitioner and the Supreme Court to support a broader interpretation protective of the child.
• RA 9262, Section 5 (Acts of Violence Against Women and Their Children) — Enumerates the punishable acts. The Supreme Court noted its use of "or" (woman or her child) to support that a child can be a victim independently.
• RA 9262, Section 8 (Protection Orders) — Defines protection orders and their purpose. The RTC interpreted this narrowly.
• RA 9262, Section 9(b) (Who May File Petition for Protection Orders) — States that "parents or guardians of the offended party" may file. Key provision used by the Supreme Court to rule that the father can file for the child.
• RA 9262, Section 28 (Custody of children) — States the "woman victim of violence" is entitled to custody. Cited by RTC to deny father's claim.
• A.M. No. 04-10-11-SC (Rule on Violence Against Women and Their Children), Section 8(b) — Incorporates RA 9262 Sec. 9(b) allowing "parents or guardians" to file.
• Rules of Court, Rule 3, Section 5 (Minor or incompetent persons) — Allows a minor to sue or be sued with the assistance of a father, mother, guardian, or guardian ad litem. Cited to support Randy's standing to file on behalf of Rhuby.
• 1987 Constitution, Article XV, Section 3(2) — States the right of children to assistance and special protection from all forms of neglect, abuse, etc. Cited to emphasize the State's duty to protect children.
• Convention on the Rights of the Child, Articles 2, 3, 9, 19, 39 — International commitments of the Philippines to protect children from violence and ensure their best interests. Cited to support a protective interpretation of RA 9262.
• Universal Declaration of Human Rights, Article 25(2) — States that motherhood and childhood are entitled to special care and assistance. Cited as part of international human rights framework.
• Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act) — Mentioned as another law protecting children, but RA 9262 provides specific remedies like protection orders not found in RA 7610.

• Leonen, SAJ. — Argues violence is a power issue, not solely a gender issue. Women can be perpetrators. RA 9262 aims to reject patriarchy, and a reductionist view of women always as victims reinforces powerlessness. Liberal reading allows a petition on behalf of the child even against the mother, consistent with the law's policy to protect both women and children. The law does not require the woman to be the victim to afford protection to the child. Section 9(b) allows parents (including fathers) to file for the child.
• Lazaro-Javier, J. — Emphasizes the trial court erred in framing the issue. The question should have been whether the father could seek a protection order on behalf of the child, not for his own benefit. Section 8 of the Rule on VAWC clearly allows parents to apply for protection orders. Child abuse can be relational (RA 9262) or non-relational (RA 7610). The Rule on VAWC deals with protection orders under RA 9262 for women and/or their children in domestic/intimate settings, and the father can invoke this on behalf of the child.

• Gesmundo, C.J. — Argues certiorari was improper; appeal was the correct remedy. On merits, posits that under RA 9262, when the offended party is a child, the mother is not the offender contemplated. The statute refers to "her child," linking the child victim to a woman who has a relationship with the offender. The present case involves only two participants (mother-offender, child-victim), not the three (offender, woman related to offender, child-victim) contemplated by the law for child victims. Believes the case should be remanded under the Rule on Custody of Minors.
• Caguioa, J. — Agrees with the RTC that RA 9262 does not cover violence by a mother against her own child. The law consistently associates "child" with the "woman" victim of violence (i.e., "her child"). The offender is the woman's intimate partner or father of her child. Legislative history shows RA 9262 was not intended for all child abuse cases (which RA 7610 covers) but specifically for violence against women and their children by the woman's partner. Argues for remand under A.M. No. 03-04-04-SC (Rule on Custody of Minors).
• Zalameda, J. — Agrees father has standing under Sec 9(b) but RA 9262 does not apply against a mother inflicting violence on her own child. RA 9262 is for gender-based violence by intimate partners. Legislative history shows a conscious choice to limit offenders. Children are incidental beneficiaries when the mother is the primary victim. Suggests remand under the Custody Rule (A.M. No. 03-04-04-SC).
• Singh, J. — While abuse is gender-blind, RA 9262's text and legislative intent limit its application to violence against a woman and "her child" by an intimate partner. A mother abusing her own child is not the scenario covered. Garcia v. Drilon allows a woman offender in same-sex relationships or conspiracy, not directly as a mother against her child. Argues for remand under the Rule on Custody of Minors (A.M. No. 03-04-04-SC).