The Importance of Financial Support in Protecting Against Economic Abuse

XXX v. People of the Philippines, G.R. No. 221370, June 28, 2021

Imagine a young mother struggling to provide for her child with special needs, unable to afford the necessary medical care because the father refuses to contribute financially. This is not just a story of personal hardship but a legal issue of economic abuse, as highlighted in the case of XXX v. People of the Philippines. The Supreme Court’s decision in this case underscores the critical role of financial support in preventing economic abuse under Republic Act No. 9262, known as the Anti-Violence Against Women and Their Children Act of 2004.

In this case, XXX was convicted for deliberately depriving his wife and child of financial support, which is a form of economic abuse. The central legal question was whether the failure to provide adequate financial support constitutes a violation of RA 9262, and if so, what the legal repercussions are for such an act.

Legal Context: Defining Economic Abuse and Support Obligations

Economic abuse, as defined under RA 9262, involves acts that make or attempt to make a woman financially dependent. This can include the withdrawal of financial support or the deprivation of financial resources. Section 5(e)(2) of the Act specifically penalizes the deprivation of financial support legally due to a woman or her child, emphasizing that such actions are considered a continuing offense.

The Family Code of the Philippines, under Article 195(4), obligates parents to support their children, covering necessities like sustenance, clothing, medical attendance, education, and transportation. This obligation is to be fulfilled in proportion to the financial capacity of the family, as stated in Article 201 of the Family Code.

For instance, if a father earns a substantial income but refuses to contribute to his child’s medical bills, this could be seen as economic abuse. The law aims to protect women and children from such financial manipulation, ensuring that they have the means to live a dignified life.

Case Breakdown: The Journey of XXX and His Family

XXX and AAA, high school sweethearts, married after AAA became pregnant with their son, BBB. Shortly after their marriage, AAA left their home due to mistreatment and returned to her parents’ house. BBB was born with Congenital Torch Syndrome, leading to delayed development and hearing impairment.

Despite knowing about BBB’s condition, XXX provided minimal financial support. AAA spent significant amounts on BBB’s medical needs, including a hearing aid costing around P35,000.00. When she sought financial help from XXX, he claimed he could not afford it, despite his income suggesting otherwise.

The case progressed through the Regional Trial Court (RTC) and the Court of Appeals (CA), both of which found XXX guilty of economic abuse. The Supreme Court upheld these decisions, emphasizing that:

“Economic abuse is one of the acts of violence punished by RA 9262… Specifically, Sec. 5, par. (e)(2) of RA 9262 penalizes the deprivation of financial support legally due the woman or child, which is a continuing offense.”

XXX’s defense that he lacked malice was dismissed by the Court, as RA 9262 classifies economic abuse as a malum prohibitum, meaning the intent is immaterial, and only the act itself is considered.

Practical Implications: Navigating Financial Responsibilities

This ruling reaffirms the legal obligation of parents to provide financial support to their children, particularly in cases involving special needs. It sets a precedent that failure to do so can be considered economic abuse under RA 9262.

For individuals facing similar situations, it is crucial to document all attempts to seek financial support and to understand the legal avenues available. This case serves as a reminder that financial support is not just a moral duty but a legal one, enforceable by law.

Key Lessons:

• Parents have a legal obligation to support their children, which includes medical and educational expenses.
• Economic abuse can be prosecuted under RA 9262, even if the deprivation of support is not malicious.
• Documenting financial transactions and communications can be crucial in legal proceedings related to support obligations.

Frequently Asked Questions

What constitutes economic abuse under RA 9262?
Economic abuse includes acts that make a woman financially dependent, such as withholding financial support or preventing her from engaging in legitimate work.

Is intent necessary to prove economic abuse?
No, RA 9262 classifies economic abuse as a malum prohibitum, meaning the act itself, not the intent, is what matters.

How can I prove that I have been economically abused?
Documentation of financial transactions, communication attempts, and any evidence of financial dependency can help prove economic abuse.

Can economic abuse be a continuing offense?
Yes, the deprivation of financial support is considered a continuing offense under RA 9262.

What should I do if I am facing economic abuse?
Seek legal advice immediately. Document all instances of withheld support and consider filing a complaint under RA 9262.

ASG Law specializes in family law and domestic violence cases. Contact us or email hello@asglawpartners.com to schedule a consultation.