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ESTEBAN DONATO REYES v. PEOPLE

FACTS:

Esteban Donato Reyes was charged with violating Section 5(i) of Republic Act No. 9262, the Anti-Violence Against Women and Their Children Act. The Regional Trial Court (RTC) found Reyes guilty and sentenced him to a minimum of three years of prision correccional and a maximum of eight years and one day of prision mayor. Reyes appealed to the Court of Appeals (CA), but his conviction was upheld.

Reyes filed a petition, arguing that the criminal Information failed to allege the punishable acts under Section 5(e), par. 2, and Section 5(i) of R.A. No. 9262, thereby violating his right to due process. The Office of the Solicitor General (OSG) countered that the Information charged Reyes with economic abuse under Section 5(e), par. 2, and that his guilt has been established by the prosecution.

The Court found Reyes' petition devoid of merit. It held that the Information against him was sufficient as it contained the essential elements of the offense charged. The Court stressed that the indictment must fully state the elements of the specific offense alleged to have been committed.

ISSUES:

  1. Whether the Information filed against the accused contained the essential elements of the crime charged.

  2. Whether the allegations in the Information sufficiently established the offense of violation of Section 5(i) of R.A. No. 9262.

  3. Whether Reyes can be held liable for violation of R.A. No. 9262 for depriving AAA of financial support.

  4. Whether Reyes can be held liable for violation of Section 5(e), par. 2 of R.A. No. 9262 for committing economic abuse against AAA.

  5. What is the appropriate penalty for the crime of violence against women and their children under Section 5(i) of Republic Act No. 9262?

  6. Should the penalty be increased if the acts are committed while the woman or child is pregnant or committed in the presence of her child?

RULING:

  1. The Information filed against the accused contained the essential elements of the crime charged. The recital of facts in the Information stated that the accused abandoned his wife without financial support, causing her psychological and emotional suffering. These facts constituted the offense of violation of Section 5(i) of R.A. No. 9262.

  2. The allegations in the Information sufficiently established the offense of violation of Section 5(i) of R.A. No. 9262. The Information clearly stated that the accused caused mental and emotional anguish to his wife through the denial of financial support. Psychological violence is an indispensable element of the offense, while mental or emotional suffering is the effect caused to the victim. The acts alleged in the Information fall within the scope of Section 5(i) of R.A. No. 9262.

  3. Reyes can be held liable for violation of R.A. No. 9262 for depriving AAA of financial support. The National Statistics Office certified copy of their marriage certificate serves as positive evidence of their marriage. Thus, Reyes has an obligation to support his wife, AAA, regardless of the status of their marriage.

  4. Reyes can also be held liable for violation of Section 5(e), par. 2 of R.A. No. 9262 for committing economic abuse against AAA. Deprivation or denial of financial support is specifically penalized under the law, and Reyes deliberately refused to provide financial support to AAA.

  5. The crime of violence against women and their children under Section 5(i) of Republic Act No. 9262 shall be punished by prision mayor.

  6. If the acts are committed while the woman or child is pregnant or committed in the presence of her child, the penalty to be applied shall be the maximum period of penalty prescribed in Section 6 of Republic Act No. 9262.

  7. In addition to imprisonment, the perpetrator shall pay a fine in the amount of not less than P100,000.00 but not more than P300,000.00 and undergo mandatory psychological counseling or psychiatric treatment.

PRINCIPLES:

  • The sufficiency of the allegations in a complaint or information is determined by whether the facts alleged, if hypothetically admitted, constitute the elements of the offense charged.

  • An indictment must fully state the elements of the specific offense alleged to have been committed.

  • The prosecution has the duty to prove each and every element of the crime charged in the Information to warrant a finding of guilt.

  • To establish psychological violence, it is necessary to prove the commission of acts enumerated in the law or similar acts. Mental or emotional suffering is the effect caused to or the damage sustained by the victim.

  • The marriage certificate is admissible as the best evidence of its contents and should be accorded full faith and credence.

  • The marriage is deemed valid until declared otherwise in a judicial proceeding, and Reyes is obliged to support his wife.

  • The offender need not be related or connected to the victim by marriage or former marriage. Someone who has or had a sexual or dating relationship with the victim can also be held liable for violence against women and their children.

  • Deprivation or denial of financial support, by itself, is already specifically penalized under R.A. No. 9262.

  • The law against violence against women and children should be liberally construed to ensure the protection and safety of the victims.

  • The court can compel an individual to comply with a temporary protection order directing the provision of financial support unless the individual can show that they are no longer employed or have no resources to provide such support.

  • The penalty for the crime of violence against women and their children under Section 5(i) of Republic Act No. 9262 is prision mayor.

  • If the acts are committed while the woman or child is pregnant or committed in the presence of her child, the penalty shall be the maximum period of penalty prescribed in Section 6 of Republic Act No. 9262.

  • In addition to imprisonment, the perpetrator shall pay a fine and undergo mandatory psychological counseling or psychiatric treatment.