The Supreme Court (SC) has ruled that filiation and deliberate withholding of financial support must be sufficiently established to sustain a conviction for economic abuse under the Anti-Violence Against Women and Their Children Act, clarifying the evidentiary requirements in cases involving alleged denial of support.  

In a decision penned by Associate Justice Japar B. Dimaampao, the Third Division acquitted a man previously convicted of violating Section 5(i) of Republic Act No. 9262, reversing the rulings of the Court of Appeals (CA) and the Regional Trial Court (RTC).  

“Here, the prosecution was unable to successfully establish that support is legally due AAA and her child and that XXX deliberately withheld the same,” the Court said in acquitting the accused for failure of the prosecution to prove guilt beyond reasonable doubt.  

FACTS AND ISSUE

The case stemmed from a complaint filed by a woman identified as AAA, who accused her former boyfriend of economic abuse for allegedly depriving her and her child of financial support legally due to them, causing emotional and psychological distress. The complaint alleged that the offense was committed in Pasay City in May 2016.  

According to the prosecution, AAA and the accused met during a high school reunion and had sexual intercourse twice in September 2015, after which she became pregnant. She claimed that the accused denied fathering the child and continuously failed to provide financial support from the time of conception until the child’s birth.  

AAA testified that she sought a DNA test to establish paternity, but no testing was conducted after disagreements arose over who would shoulder the expenses. She also presented the child’s birth certificate, a demand letter for support, and photographs of the child.  

For his defense, the accused denied fathering the child and said no DNA test was conducted because the parties failed to agree on who would shoulder the expenses.  

The Pasay City RTC convicted the accused of economic abuse under Section 5(i) of RA 9262 and sentenced him to imprisonment, a fine of P100,000, and mandatory psychological counseling.  

The CA later affirmed the conviction, holding that the prosecution established the elements of the offense and that proof of paternity was not an essential element of the crime.  

Before the SC, the accused argued that the prosecution failed to prove the elements of the offense, particularly that he willfully withheld financial support to inflict emotional anguish. He also continued to deny paternity.  

The core issue before the SC was whether the accused violated Section 5(i) of RA 9262 by allegedly denying financial support.  

RULING

Granting the petition, the SC reversed and set aside the rulings of the CA and RTC and acquitted the accused for failure of the prosecution to prove guilt beyond reasonable doubt.  

The Court held that the prosecution failed to establish the second and fourth elements required for conviction under Section 5(i) of RA 9262.  

The SC ruled that the child’s unsigned birth certificate could not sufficiently establish filiation and noted the absence of proof that the accused acknowledged the child.  

“Support follows as a matter of obligation when filiation is beyond question,” the Court said.  

The SC also noted that the accused questioned the child’s lineage and did not outright refuse DNA testing.  

“Evidently, XXX did not willfully refuse to provide financial support for the purpose of inflicting psychological violence upon AAA or her child,” the Court ruled.

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