Reyes vs. People

Denial of financial support legally due to a wife, which causes her mental or emotional anguish, constitutes psychological violence punishable under Section 5(i) of R.A. No. 9262, and the Information charging such offense is sufficient if it alleges the marital relationship (or qualifying relationship under the Act), the act of withholding support, and the resulting psychological suffering, notwithstanding the accused's claim that the marriage is void where no judicial declaration of nullity exists.

Esteban Donato Reyes and AAA were married on May 15, 1969, a union that produced four children. Reyes worked as a pilot, initially for the Philippine Air Force and later as a commercial aviator based abroad. While the marriage subsisted, Reyes allegedly entered into a second marriage with Marilou Osias Ramboanga, with whom he had four children. In July 2005, Reyes ceased providing the monthly financial support of ₱10,000.00 to ₱20,000.00 that he had previously extended to AAA. At the time of the filing of the complaint, AAA suffered from hypertension, cardiovascular disease, diabetes, and osteoarthritis, requiring regular medical attention and maintenance medication.

• The Charge: An Information dated June 5, 2006 was filed before the Regional Trial Court (RTC) of Quezon City, initially designating the offense as violation of Section 5(e), paragraph 2 of R.A. No. 9262 (economic abuse). The accusatory portion alleged that Reyes, "willfully, unlawfully and feloniously commit economic abuse upon his wife, AAA, by then and there abandoning her without any financial support thereby depriving her of her basic needs and inflicting upon her psychological and emotional suffering."
• Provisional Remedies: On March 12, 2007, the RTC issued a Temporary Protection Order (TPO) directing Reyes to resume delivering monthly financial support of ₱20,000.00 to AAA, reckoned from July 2005. On August 30, 2007, a Hold Departure Order (HDO) was issued, and on October 28, 2008, the TPO was made permanent.
• Motion to Quash: On June 11, 2009, Reyes filed a Motion to Quash arguing that "abandoning without financial support" is not criminalized under R.A. No. 9262 and that the Information failed to charge an offense, violating his right to due process. The prosecution opposed, maintaining that the facts constituted violation of Section 5(e), paragraph 2.
• RTC Ruling on Motion: In an Order dated November 24, 2009, the RTC denied the Motion to Quash but directed the amendment of the Information to properly designate the crime as violation of Section 5(i) of R.A. No. 9262 (psychological violence), finding that the allegations described psychological violence rather than economic abuse. Reyes was arraigned under the amended Information and pleaded not guilty.
• Prosecution Evidence: AAA testified that Reyes stopped providing support in July 2005, leaving her unable to meet medical expenses for her chronic illnesses. Her attending physician, Dr. Rey Caesar R. Anunciacion, and her daughter corroborated her testimony regarding her physical and emotional deterioration.
• Defense Evidence: Reyes testified that he never married AAA, claiming his signature on the marriage certificate was forged and that he was only twenty years old in 1969 (born 1948), rendering the document void. He characterized their union as a common-law relationship. He admitted stopping support in July 2006 (not 2005) because AAA filed a bigamy case against him, which he deemed ingratitude. He claimed to have provided Christmas bonuses, paid for her cataract operation and dentures, and funded their grandchildren's education. He asserted he lost his pilot employment in 2007 due to the HDO.

• Sufficiency of the Information: The Information failed to allege the essential elements of either Section 5(e), paragraph 2 or Section 5(i) of R.A. No. 9262. The phrase "abandoning without financial support" does not constitute the crime of deprivation of financial support, rendering the Information void for failure to inform him of the nature and cause of the accusation.
• Validity of Marriage and Absence of Legal Duty: No valid marriage existed between Reyes and AAA; the marriage certificate contained forged signatures and incorrect age data. Absent a valid marriage, no legal obligation to support arose, precluding liability for denial of support under the VAWC.
• Justification for Withholding Support: The cessation of support in July 2006 (disputing the 2005 date) was justified by AAA's filing of a bigamy case, which constituted ingratitude and harassment.

• Sufficiency of the Information: The Information sufficiently alleged economic abuse under Section 5(e), paragraph 2 by charging abandonment and deprivation of financial support. The amendment to Section 5(i) was proper as the facts alleged—denial of support causing psychological suffering—clearly fell within the scope of psychological violence.
• Applicability of VAWC Regardless of Marital Status: Even assuming the marriage was void, R.A. No. 9262 applies to women with whom the accused has a common child, which Reyes and AAA have.
• Existence of Criminal Intent: The denial of financial support was calculated to control AAA's conduct, pressure her to withdraw the bigamy case, and dissuade her from pursuing her legal rights, thereby constituting both economic abuse and psychological violence.

• Sufficiency of the Information: Whether the Information dated June 5, 2006 sufficiently alleged the elements of violation of Section 5(i) of R.A. No. 9262 to withstand a motion to quash.
• Liability Despite Claim of Void Marriage: Whether Reyes may be held criminally liable for denial of financial support despite his claim that the marriage to AAA was void ab initio.
• Proper Penalty: Whether the indeterminate penalty imposed by the trial court and affirmed by the Court of Appeals is in accordance with law.

• Sufficiency of the Information: The Information was sufficient. It alleged that AAA is the wife of Reyes, that Reyes abandoned her without financial support, and that such deprivation caused psychological and emotional suffering. These allegations hypothetically admitted, constitute the elements of violation of Section 5(i): (1) the offended party is a woman who is the wife of the offender; (2) the offender causes mental or emotional anguish; and (3) such anguish is caused through denial of financial support. The designation of the offense under Section 5(e) was a formal defect cured by amendment before arraignment, and the substance of the charge remained clear throughout.
• Liability Independent of Marriage Validity: Liability attaches notwithstanding the claim of void marriage. A certified copy of the marriage certificate from the National Statistics Office constitutes prima facie evidence of a valid marriage, which stands until judicially declared void. Furthermore, Section 5(i) of R.A. No. 9262 applies to any woman with whom the offender has or had a sexual or dating relationship or with whom he has a common child. Reyes and AAA have four children, bringing their relationship squarely within the Act's coverage regardless of the marriage's validity.
• Psychological Violence Established: The prosecution proved that Reyes' deliberate denial of financial support, commencing July 2005 while he remained gainfully employed, caused AAA mental and emotional anguish manifested in the deterioration of her physical health. Psychological violence is the means employed; mental or emotional suffering is the resulting damage. The denial was designed to subjugate AAA's will and control her conduct by pressuring her to withdraw the bigamy case, thereby satisfying the element of intent to cause anguish.
• Penalty Modification: The penalty for violation of Section 5(i) is prision mayor under Section 6 of R.A. No. 9262. Applying the Indeterminate Sentence Law and Article 64 of the Revised Penal Code (no aggravating or mitigating circumstances), the proper penalty is four years and two months of prision correccional as minimum to eight years and one day of prision mayor as maximum. Additionally, Reyes is ordered to pay a fine of ₱200,000.00 and undergo mandatory psychological counseling or psychiatric treatment.

• Elements of Psychological Violence under Section 5(i) of R.A. No. 9262 — The offense requires: (1) the offended party is a woman and/or her child or children; (2) the woman is the wife or former wife of the offender, or has or had a sexual or dating relationship with him, or has a common child with him; (3) the offender causes mental or emotional anguish to the woman and/or child; and (4) such anguish is caused through acts of public ridicule, humiliation, repeated verbal and emotional abuse, denial of financial support or custody of minor children, or similar acts or omissions. (Citing Dinamling v. People)
• Distinction Between Psychological Violence and Mental/Emotional Anguish — Psychological violence constitutes the means or vehicle employed by the perpetrator, while mental or emotional suffering represents the effect caused to or the damage sustained by the offended party. Both are essential elements requiring independent proof.
• Presumption of Marriage Validity — A marriage certificate issued by the National Statistics Office enjoys the presumption of regularity and constitutes prima facie evidence of the marriage's existence and validity until declared void by a competent court in a judicial proceeding.
• VAWC Coverage Beyond Formal Marriage — R.A. No. 9262 protects women in sexual or dating relationships and those with whom the offender shares a common child, irrespective of the existence or validity of marriage.
• Sufficiency of Information Test — An Information is sufficient if the facts alleged, if hypothetically admitted, constitute the elements of the offense defined by the statute. The test is whether the accused is informed of the nature and cause of the accusation to enable him to prepare his defense.

• "Psychological violence is certainly an indispensable element of violation of Section 5(i) of R.A. No. 9262. Equally essential is the element of the mental or emotional anguish which is personal to the complainant. Psychological violence is the means employed by the perpetrator, while mental or emotional suffering is the effect caused to or the damage sustained by the offended party."
• "Reyes will not be exonerated even assuming that his marriage is declared void ab initio by the court. R.A. No. 9262 defines and criminalizes violence against women and their children perpetrated by the woman's husband, former husband or any person against whom the woman has or had a sexual or dating relationship with, or with whom the woman has a common child..."
• "Evidently, the denial of financial support is designed to subjugate AAA's will and control her conduct, either to pressure her to withdraw said criminal case for Bigamy or dissuade her from pursuing it, or at least, to discourage her from filing additional cases against him."

• Dinamling v. People, 761 Phil. 356 (2015) — Enumerated the four essential elements of violation of Section 5(i) of R.A. No. 9262.
• Tenebro v. Court of Appeals, 467 Phil. 723 (2004) — Held that a marriage certificate is admissible as the best evidence of its contents and enjoys presumption of validity.
• Melgar v. People, G.R. No. 223477, February 14, 2018 — Affirmed that deprivation of financial support legally due constitutes economic abuse under Section 5(e) of R.A. No. 9262.
• AAA v. BBB, G.R. No. 212448, January 11, 2018 — Distinguished psychological violence as the means from mental/emotional anguish as the effect.
• Go-Tan v. Spouses Tan, 588 Phil. 532 (2008) — Mandated liberal construction of R.A. No. 9262 to ensure protection of victims.

• Section 5(i), R.A. No. 9262 — Penalizes causing mental or emotional anguish through denial of financial support or custody of minor children.
• Section 3(c), R.A. No. 9262 — Defines psychological violence as acts or omissions causing or likely to cause mental or emotional suffering.
• Section 5(e), par. 2, R.A. No. 9262 — Defines economic abuse to include depriving the woman of financial support legally due her.
• Section 6, R.A. No. 9262 — Prescribes the penalty of prision mayor for acts under Section 5(i).
• Section 6, Rule 110, Rules of Court — States the requisites for sufficiency of an Information.
• Article 64, Revised Penal Code — Governs the application of penalties when there are no aggravating or mitigating circumstances.

Leonen, A. Reyes, Jr., Hernando, and Inting, JJ.