This Supreme Court decision clarifies that the protection afforded to women under Republic Act (RA) No. 9262, the Anti-Violence Against Women and Their Children Act, extends even to situations where a dating relationship has ended. The Court emphasizes that the law’s intent is to protect women from violence, regardless of the relationship’s current status. The ruling affirms that violence occurring after a relationship’s termination can still fall under RA 9262, ensuring that the law remains a potent tool against abuse. This means that acts of violence committed by a former partner can still be prosecuted under this law, providing broader protection for victims and reinforcing the state’s commitment to safeguarding women’s rights. The decision underscores that the existence of a past relationship is a critical factor, broadening the scope of protection.

When Does a Breakup Not Break the Law? RA 9262 and the Scope of Protection for Women

The case of Karlo Angelo Dabalos y San Diego v. Regional Trial Court, Branch 59, Angeles City (Pampanga), et al., G.R. No. 193960, decided on January 7, 2013, revolves around the interpretation of Republic Act (RA) No. 9262, also known as the Anti-Violence Against Women and Their Children Act of 2004. The central question is whether RA 9262 applies to acts of violence committed after a dating relationship has ended. This case highlights the scope of protection offered by the law and clarifies when acts of violence fall under its purview. The petitioner, Karlo Angelo Dabalos, was charged with violating Section 5(a) of RA 9262 for allegedly inflicting physical injuries on his former girlfriend. The petitioner argued that because their dating relationship had ended before the incident, RA 9262 was not applicable.

The Regional Trial Court (RTC) found probable cause and issued a warrant of arrest, leading Dabalos to file a Motion for Judicial Determination of Probable Cause with a Motion to Quash the Information. This motion was denied, prompting Dabalos to elevate the matter to the Supreme Court. At the heart of the legal challenge was the interpretation of Section 3(a) of RA 9262, which defines “Violence against women and their children.”

SEC. 3. Definition of Terms.– As used in this Act, (a) “Violence against women and their children” refers to any act or a series of acts committed by any person against a woman who is his wife, former wife, or against a woman with whom the person has or had a sexual or dating relationship, or with whom he has a common child, or against her child whether legitimate or illegitimate, within or without the family abode, which result in or is likely to result in physical, sexual, psychological harm or suffering, or economic abuse including threats of such acts, battery, assault, coercion, harassment or arbitrary deprivation of liberty. x x x.

The Supreme Court upheld the RTC’s decision, emphasizing that RA 9262’s protection extends to women who have had a dating relationship with the offender, regardless of whether the relationship was ongoing at the time of the violent act. The Court underscored that the law does not require the act of violence to be a direct consequence of the relationship itself. The key factors are the existence of a past or present relationship and the commission of an act of violence resulting in physical, sexual, or psychological harm.

Building on this principle, the Supreme Court referenced the case of Ang v. Court of Appeals, where the elements of violence against women through harassment were enumerated. These elements include the existence of a sexual or dating relationship, the commission of harassment, and the resulting emotional or psychological distress to the woman. The Court clarified that while a prior or current relationship is necessary for RA 9262 to apply, the act of violence need not arise directly from that relationship. This interpretation broadens the scope of RA 9262, ensuring that women are protected from violence even after a relationship has ended.

The Court rejected the petitioner’s argument that the act should be treated as slight physical injuries under the Revised Penal Code, which would fall under the jurisdiction of the Municipal Trial Court. The Supreme Court affirmed that RA 9262 prescribes a higher penalty for acts of violence against women with whom the offender has or had a sexual or dating relationship, reflecting the legislative intent to provide greater protection to women and children. This approach contrasts with a simple application of the Revised Penal Code, underscoring the specialized protection RA 9262 offers.

The decision also addressed the issue of amending the Information. The RTC’s order, giving the prosecutor time to amend the Information to reflect the cessation of the dating relationship, was deemed proper under the Rules of Court. Specifically, Section 4 of Rule 117 allows for amendments to cure defects in the complaint or information, and Section 14 of Rule 110 permits amendments before the accused enters a plea. Given that Dabalos had not yet been arraigned, the RTC’s directive to amend the Information was deemed appropriate and within the bounds of procedural law.

Petitioner’s Argument	Court’s Reasoning
RA 9262 does not apply because the dating relationship had ended before the incident.	RA 9262 applies as long as there was a past or present dating relationship, regardless of its status at the time of the violence.
The act should be treated as slight physical injuries under the Revised Penal Code.	RA 9262 prescribes a higher penalty for violence against women, reflecting legislative intent to provide greater protection.

Furthermore, the Court explicitly rejected the application of the rule of lenity, which favors a more lenient punishment when a criminal statute is ambiguous. The Court found no ambiguity in RA 9262, stating that the law clearly intends to impose a more severe sanction on offenders who harm women with whom they have or had a sexual or dating relationship. This decision reinforces the legislative intent behind RA 9262 to prioritize the protection of women and children in such relationships.

Ultimately, the Supreme Court’s decision in Dabalos v. RTC serves as a significant affirmation of the protective scope of RA 9262. By clarifying that the law applies even when a dating relationship has ended, the Court ensures that women are not left vulnerable to abuse simply because a relationship has terminated. This ruling underscores the state’s commitment to protecting women and children from violence, regardless of the specific circumstances of the relationship.

FAQs

What was the key issue in this case?	The key issue was whether RA 9262 applies to acts of violence committed after a dating relationship has ended. The Court clarified that the law’s protection extends to women even after the termination of the relationship.
What is Section 3(a) of RA 9262?	Section 3(a) defines “Violence against women and their children” and includes acts committed against a woman with whom the person has or had a sexual or dating relationship. This definition is central to determining the applicability of RA 9262.
Does the act of violence need to be a consequence of the relationship for RA 9262 to apply?	No, the Court clarified that the act of violence does not need to be a direct consequence of the relationship. The existence of a past or present relationship is sufficient.
What was the petitioner’s argument in this case?	The petitioner argued that RA 9262 did not apply because the dating relationship had ended before the incident. He also argued that the act should be treated as slight physical injuries under the Revised Penal Code.
How did the Court address the petitioner’s argument?	The Court rejected the petitioner’s argument, stating that RA 9262 applies as long as there was a past or present dating relationship. The Court also emphasized that RA 9262 prescribes a higher penalty for violence against women.
What is the significance of the Ang v. Court of Appeals case in this context?	The Ang case provides the elements of violence against women through harassment, which the Court used to clarify that the act of violence need not arise directly from the relationship for RA 9262 to apply.
Why did the Supreme Court reject the application of the rule of lenity?	The Supreme Court rejected the rule of lenity because it found no ambiguity in RA 9262. The law clearly intends to impose a more severe sanction on offenders who harm women with whom they have or had a sexual or dating relationship.
What was the outcome of the case?	The Supreme Court dismissed the petition and affirmed the Orders of the Regional Trial Court, emphasizing that RA 9262’s protection extends to women who have had a dating relationship with the offender, regardless of whether the relationship was ongoing at the time of the violent act.

This case provides a clear legal precedent for the application of RA 9262 in cases where violence occurs after the termination of a dating relationship. It reinforces the importance of protecting women from violence, regardless of their relationship status, and provides a framework for interpreting and applying RA 9262 in similar situations.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: KARLO ANGELO DABALOS Y SAN DIEGO, VS., G.R. No. 193960, January 07, 2013