06/05/2026
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The has acquitted a man charged with violence against women and their children, or VAWC, for allegedly refusing to provide financial support to a child not proven to be his, emphasizing that a legal duty to provide financial support arises only after filiation or paternity has been established.
In a Decision written by Associate Justice Japar B. Dimaampao, the SCโs Third Division reversed the rulings of the Regional Trial Court and the Court of Appeals, which found the accused guilty of economic abuse under Republic Act No. 9262, or the ๐๐ฏ๐ต๐ช-๐๐ช๐ฐ๐ญ๐ฆ๐ฏ๐ค๐ฆ ๐๐จ๐ข๐ช๐ฏ๐ด๐ต ๐๐ฐ๐ฎ๐ฆ๐ฏ ๐ข๐ฏ๐ฅ ๐๐ฉ๐ฆ๐ช๐ณ ๐๐ฉ๐ช๐ญ๐ฅ๐ณ๐ฆ๐ฏ ๐๐ค๐ต ๐ฐ๐ง 2004 (๐๐ฏ๐ต๐ช-๐๐๐๐ ๐๐ค๐ต).
The case arose from a complaint filed by a woman against her former boyfriend, accusing him of refusing to provide financial support for her child.
The accused consistently denied he was the father, claiming that the child was born only eight months after they last had sexual relations.
During trial, the woman presented the childโs birth certificate as evidence. However, the portion indicating the fatherโs name, was marked "๐/๐" and left unsigned.
The woman also admitted in court that the accused refused to give financial support because he doubted that he was the childโs father.
In reversing the accusedโs conviction, the SC explained that to convict a person for economic abuse under Section 5(i) of the ๐๐ฏ๐ต๐ช-๐๐๐๐ ๐๐ค๐ต, the prosecution must show the following: (1) the victim is a woman and/or her child; (2) the woman is the offenderโs wife or partner, or someone with whom the offender has a common child; (3) the offender refused to give financial support due; and (4) the refusal was intended to cause mental or emotional suffering.
In this case, the SC ruled that the prosecution failed to prove two essential elements: that the accused and the woman share a common child, and that the refusal to provide support was done to inflict psychological harm.
As the accusedโs paternity was not proven in this case, no legal obligation to provide support could be imposed.
Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=164663.
Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164655.
Copying of this content is subject to the SC PIOโs Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution.
