Sandra Jane Gagu Jacinto vs. Maria Eloisa Sarmiento Fouts

The Court held that an order denying a motion to quash is interlocutory and unappealable under the Rules of Court, requiring the accused to proceed to trial and raise the issue on appeal from a final judgment. Substantively, the Court ruled that Republic Act No. 9262 encompasses lesbian relationships because Section 3(a) employs the unqualified, gender-neutral term "any person" to define the offender, and the legislative history expressly confirms Congress's intent to protect women from intimate partner violence irrespective of sexual orientation.

Sandra Jane Gagui Jacinto and Maria Eloisa Sarmiento Fouts maintained a sixteen-year relationship before separating in December 2017. Following the separation, disputes arose over shared property, a three-million-peso debt, and credit card usage. Fouts alleged that Jacinto threatened to destroy their residence, caused her chest pain through intimidation, and later forced her to ingest medication. On January 14, 2018, Fouts alleged that Jacinto pushed her forcefully and repeatedly crushed her hands with a car door, resulting in a left wrist fracture requiring surgery. Jacinto maintained that the criminal complaint was filed as leverage for a pending civil case for reconveyance, and asserted that Fouts initiated physical contact and fell while attempting to prevent Jacinto from leaving.

• Jacinto and Fouts cohabited for sixteen years before their separation in December 2017. Fouts alleged that Jacinto subsequently demanded that she vacate their Antipolo City residence and execute a deed of absolute sale over the property. When Fouts refused, Jacinto allegedly threatened to burn the house, causing Fouts to experience chest pain and respiratory difficulty. Fouts further alleged that on January 14, 2018, after regaining consciousness from medication, she discovered Jacinto taking non-consensual photographs of her. Upon following Jacinto to her vehicle, Fouts claimed Jacinto pushed her and repeatedly crushed her hands with the car door, causing a fractured left wrist. Jacinto countered that the criminal complaint was a retaliatory measure for a pending civil reconveyance case. She asserted that Fouts initiated the encounter, requested photographs, became hysterical when asked to delete them, and fell to the ground while attempting to physically restrain Jacinto. The prosecution subsequently filed an Information charging Jacinto with violation of Section 5(a) in relation to Section 6(a) of RA 9262. Jacinto moved to quash the Information, contending that the statute does not govern same-sex relationships.

• Petitioner maintained that RA 9262 does not apply to lesbian relationships and argued that the trial court misapplied Garcia v. Drilon by treating its discussion of same-sex couples as binding precedent rather than obiter dictum. Petitioner invoked the principle of ejusdem generis, asserting that the statutory enumeration in Section 3(a) references male counterparts, thereby limiting the term "any person" to men. She contended that applying the statute to female perpetrators would create a statutory imbalance where one partner receives protection while the other is denied it. Petitioner further argued that pending congressional amendments to explicitly include "partners" demonstrate that same-sex relationships currently fall outside the law's coverage. She characterized the Rule 45 petition as proper because it raises a pure question of law regarding statutory construction and sought injunctive relief to prevent an allegedly defective trial from proceeding.

• Respondent countered that the Rule 45 petition constitutes an improper remedy because an order denying a motion to quash is an unappealable interlocutory order. She argued that the plain language of RA 9262 leaves no ambiguity, as the term "any person" expressly encompasses individuals of any gender who share a dating or sexual relationship with the victim. Respondent maintained that the Supreme Court's pronouncement in Garcia v. Drilon constitutes ratio decidendi because it directly addressed an equal protection challenge to the statute's classification of offenders. She opposed the issuance of a temporary restraining order, asserting that petitioner failed to demonstrate a clear and unmistakable right to relief and that the petition lacks substantive merit.

• Procedural Issues: Whether a Petition for Review on Certiorari under Rule 45 is the proper remedy to assail a trial court order denying a motion to quash a criminal information.
• Substantive Issues: Whether Republic Act No. 9262 applies to acts of violence committed by a woman against her female live-in partner within a lesbian relationship.

• Procedural: The Court dismissed the petition as an improper remedy. Pursuant to Section 1, Rule 41 of the Rules of Court, an order denying a motion to quash is interlocutory and does not terminate the proceedings, rendering it unappealable. Following Enrile v. Manalastas, the proper course is for the accused to enter a plea, proceed to trial, and assign the denial of the motion as error upon appeal from a final judgment. The Court further noted that even if construed as a Rule 65 petition, the filing directly before the Supreme Court would warrant dismissal for violating the hierarchy of courts.
• Substantive: The Court held that RA 9262 applies to lesbian relationships. Section 3(a) defines the offense as acts committed by "any person" against a woman with whom the person has or had a sexual or dating relationship. The Court found the statutory language unambiguous and gender-neutral, encompassing female perpetrators. The Court clarified that its prior ruling in Garcia v. Drilon on this precise scope constitutes ratio decidendi, not obiter dictum, as it resolved a constitutional challenge to the law's classification. The Court further relied on the explicit legislative intent recorded in the Bicameral Conference Committee deliberations, which confirmed that Congress intended the law to cover woman-to-woman relationships. Accordingly, the motion to quash lacked merit, and the petition was denied.

• Interlocutory Orders Doctrine — An order that does not dispose of the case on the merits or leave nothing more to be done by the trial court is interlocutory and unappealable. The Court applied this doctrine to bar the Rule 45 petition, directing the petitioner to proceed to trial and elevate the issue only upon final judgment.
• Plain Meaning Rule and Legislative Intent — Where statutory language is clear and unambiguous, courts must apply it according to its ordinary meaning without resorting to interpretation. The Court applied this rule to Section 3(a) of RA 9262, finding that "any person" requires no qualification. It further corroborated the plain text with the Bicameral Conference Committee's explicit intent to include lesbian relationships, thereby foreclosing statutory construction that would limit coverage to male perpetrators.
• Equal Protection Clause — The constitutional guarantee of equal protection requires that all persons similarly situated receive uniform treatment, and classifications must rest on substantial distinctions relevant to a legitimate state objective. The Court, through the concurring opinion, held that withholding RA 9262 protections from women in same-sex relationships constitutes arbitrary discrimination, as intimate partner violence inflicts identical harm regardless of the perpetrator's gender, and superficial differences in sexual orientation do not justify exclusion from statutory protection.

• "Where the law is clear, there is no room for interpretation; there is only room for application." — Justice Singh invoked this principle to emphasize that Section 3(a)'s use of "any person" is unequivocal and mandates coverage of female perpetrators without requiring judicial expansion or limitation.
• "The remedy against the denial of a motion to quash is for the movant accused to enter a plea, go to trial, and should the decision be adverse, reiterate on appeal from the final judgment and assign as error the denial of the motion to quash." — Cited from Enrile v. Manalastas to establish the mandatory procedural pathway and justify the dismissal of the premature Rule 45 petition.
• "The use of the gender-neutral word 'person' who has or had a sexual or dating relationship with the woman encompasses even lesbian relationships." — Extracted from Garcia v. Drilon and reiterated by the Court to confirm that the statute's protective scope was never intended to be restricted to heterosexual dynamics, thereby foreclosing the petitioner's ejusdem generis argument.

• Garcia v. Drilon, 712 Phil. 44 (2013) — Followed as controlling precedent to affirm that RA 9262 covers lesbian relationships and to establish that the Court's prior discussion on the matter constitutes binding ratio decidendi resolving an equal protection challenge, rather than incidental commentary.
• Enrile v. Manalastas, 746 Phil. 43 (2014) — Cited to define the exclusive procedural remedy against a denied motion to quash, mandating trial continuation and appellate review only after a final judgment.
• Biraogo v. Philippine Truth Commission, 651 Phil. 374 (2010) — Referenced in the concurring opinion to articulate the constitutional standard for equal protection, establishing that the state may not impose classifications based on characteristics irrelevant to a legitimate governmental purpose.

• Republic Act No. 9262, Section 3(a) — Defines "violence against women and their children" as acts committed by "any person" against a woman sharing a sexual or dating relationship with the offender, serving as the textual foundation for extending the law to same-sex relationships.
• Republic Act No. 9262, Section 5(a) — Penalizes the act of causing physical harm to a woman or her child, providing the specific substantive basis for the criminal information filed against the petitioner.
• Rules of Court, Section 1, Rule 41 — Enumerates unappealable orders, including interlocutory orders, forming the procedural basis for dismissing the Rule 45 petition.
• 1987 Constitution, Article III, Section 1 — Invoked to underscore the constitutional mandate of equal protection, prohibiting arbitrary discrimination against women based on their partner's gender.

• Justice Singh — Concurred on both procedural and substantive grounds while expanding on the constitutional and jurisprudential dimensions of the ruling. Justice Singh emphasized that excluding lesbian relationships from RA 9262 would violate the Equal Protection Clause by discriminating against a class of women based on sexual orientation. He detailed the legislative history of the Bicameral Conference Committee, which explicitly recorded its intent to cover woman-to-woman relationships to prevent future judicial misinterpretation. He further argued that the law's purpose to eradicate intimate partner violence necessitates gender-blind application regarding the perpetrator, and that recognizing female agency and liability aligns with substantive gender equality. Justice Singh anchored his concurrence in broader constitutional principles of autonomy and non-discrimination, citing prior progressive rulings on gender and family diversity to reinforce that statutory protection must adapt to lived realities without reinforcing heteronormative biases.