The Supreme Court (SC) has acquitted a man previously convicted of economic abuse under Republic Act No. 9262, ruling that paternity must first be established before a person can be held criminally liable for failing to provide financial support.
In a decision penned by Associate Justice Japar B. Dimaampao, the Court’s Third Division reversed the earlier rulings of the Regional Trial Court (RTC) and the Court of Appeals (CA), which found the accused guilty of violating the Anti-Violence Against Women and Their Children (VAWC) Law.
The case stemmed from a complaint filed by a woman against her former boyfriend, accusing him of refusing to provide financial support for her child.
The accused denied paternity, arguing that the child was born eight months after their last sexual encounter. While both parties had considered DNA testing to settle the issue, it was never carried out due to disagreements over the cost.
During the trial, the prosecution presented the child’s birth certificate, but it failed to identify the father, as the relevant portion was marked “N/A” and left unsigned. The woman also admitted that the accused refused financial support because he questioned his paternity.
Despite this, the lower courts convicted the accused, giving greater weight to the woman’s testimony and ruling that proof of paternity was not necessary to establish economic abuse.
The Supreme Court disagreed, clarifying that for a conviction under Section 5(i) of the Anti-VAWC law, the prosecution must prove that the offender and the woman share a common child, among other elements. It stressed that a legal obligation to provide financial support arises only after filiation or paternity has been clearly established.
The High Court found that the prosecution failed to prove two key elements: the existence of a common child between the parties and that the accused’s refusal to provide support was intended to inflict psychological or emotional harm.
The Court further emphasized that even if paternity had been proven, criminal liability would still require clear evidence that the refusal to give support was done deliberately to cause suffering—an element also absent in this case.
As a result, the accused was acquitted, with the ruling underscoring the necessity of establishing paternity before enforcing financial obligations under the Anti-VAWC law.
