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KARLO ANGELO DABALOS Y SAN DIEGO v. RTC

FACTS:

The case involves a petition challenging the denial of a motion to quash the Information filed against the petitioner. The petitioner was charged with violation of Section 5(a) of Republic Act (RA) No. 9262, otherwise known as the Violence Against Women and Their Children Act. The Information alleged that the petitioner, who was the boyfriend of the complainant, willfully and unlawfully used personal violence on the complainant, causing physical injuries and demeaning her intrinsic worth and dignity. The Regional Trial Court (RTC) denied the petitioner's motion, ruling that the offense fell within the scope of RA 9262. The petitioner argued that RA 9262 was inapplicable because his dating relationship with the complainant had already ended at the time of the incident. The Court ruled that for the law to be applicable, it is not necessary that the act of violence result from the dating relationship. The Court also held that there was no ambiguity in RA 9262 that would warrant a rule of lenity in favor of the petitioner. Thus, the offense was covered by RA 9262, and the RTC had jurisdiction over the case. The Court also found that the RTC's order to amend the Information was in accordance with the Rules of Court. The petition was dismissed, and the RTC was directed to continue with the proceedings.

ISSUES:

  1. Whether the RTC has jurisdiction over the offense;

  2. Whether RA 9262 should be construed in a manner that will favor the accused;

  3. Whether the Information alleging a fact contrary to what has been admitted should be quashed.

RULING:

  1. The petition is dismissed. The Orders of the RTC denying petitioner's motion and directing the amendment of the Information are affirmed.

PRINCIPLES:

  • The Court will not read into Republic Act (RA) No. 9262 a provision that would render it toothless in the pursuit of the declared policy of the State to protect women and children from violence and threats to their personal safety and security.

  • For RA 9262 to be applicable, it is not indispensable that the act of violence be a consequence of a sexual or dating relationship. The law covers all acts of violence against women with whom the offender has or had a sexual or dating relationship.

  • The court shall order that an amendment be made if the motion to quash is based on an alleged defect of the complaint or information which can be cured by amendment.

  • An information may be amended, in form or in substance, without leave of court, at any time before the accused enters his plea.