Paternity Must Be Proven to Convict for Economic Abuse Under Anti-VAWC Law

The Supreme Court has repeatedly clarified the strict boundaries of prosecuting economic abuse under the Anti-Violence Against Women and Their Children Act, ensuring that the law serves as a shield for genuine victims rather than a tool for unjust criminal liability. In cases involving claims for child support between unmarried partners, the prosecution cannot merely rely on allegations of emotional distress to secure a conviction for economic abuse.

The law explicitly demands that a legal obligation to provide financial support must exist before its withholding can be penalized as a criminal offense. In the case of XXX vs. People of the Philippines, G.R. No. 262419, November 03, 2025, the High Tribunal has established that a regular dispute over an unproven biological relationship falls outside the scope of criminal economic abuse, emphasizing that the state must first establish legal filiation through recognized statutory methods.

The petitioner, XXX, met the private complainant, AAA, at a high school reunion, and the two subsequently engaged in sexual relations twice in September 2015. Following these encounters, AAA became pregnant and immediately informed XXX, who denied fathering the child. AAA gave birth to BBB and continuously demanded financial support, which XXX failed to provide. While AAA proposed a DNA test to settle the paternity issue, the parties never conducted one because XXX wanted to split the expenses due to financial difficulties, whereas AAA and her father insisted that XXX assume the entire cost.

During the trial, AAA presented the child’s Certificate of Live Birth as evidence, but the section for the father's information was marked "N/A" and left unsigned. AAA further admitted during cross-examination that XXX denied financial support specifically because he doubted the child's lineage and that they could not reach an agreement regarding the costs of the DNA test.

The Regional Trial Court convicted XXX of economic abuse under Section 5(i) of Republic Act No. 9262, ruling that his denial carried less weight than AAA's testimony, and the Court of Appeals affirmed this conviction after declaring that proof of paternity is not an element of the crime.

The Supreme Court reversed the lower court decisions by applying the established legal framework for economic abuse under Section 5(i) of Republic Act No. 9262.
Citing Acharon v. People of the Philippines, the High Tribunal outlined the specific standards required for a conviction. It explained that to convict a person for economic abuse under Section 5(i) of the Anti-VAWC Act, the prosecution must show that: (1) the victim is a woman and/or her child; (2) the woman is the offender’s 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.

A perusal of the accusatory portion of the Information shows that the charge is anchored on AAA's firm belief that XXX is BBB's father. It is undisputed that XXX and AAA had sexual relations out of wedlock and the controversy rests on BBB's filiation.

Moreover, when a birth certificate is used as proof of filiation, the same should be signed by both the mother and father. In People v. Delantar, Simplicio Delantar was convicted for violating Section 5(a) of Republic Act No. 9165. He offered AAA to clients for prostitution and subjected her to physical violence to instill fear. One of the pieces of evidence presented was AAA's birth certificate showing that Delantar was her father. In determining the appropriate penalty, the Court did not give credence to the birth certificate given that it was unsigned by Delantar.

In the instant case, apart from AAA's testimony, BBB's Certificate of Live Birth was adduced as evidence. However, it is readily apparent that the space for the father's information indicates "N/A" or "not applicable" and was left unsigned. There is also a dearth of evidence to establish that XXX acknowledged the child as his own. With XXX's liberty at stake, the birth certificate cannot be given weight as proof of paternity. It bears stressing that support follows as a matter of obligation when filiation is beyond question. With the prosecution's failure to prove the second element that AAA and XXX share a common child, there is serious doubt on whether financial support is legally due AAA or her child.

At any rate, even if the Court were to consider AAA's narration, well-settled is the rule that mere failure to provide financial support does not automatically result in criminal liability. The Court elucidated in Acharon that there must be evidence on record that the accused willfully or consciously withheld financial support legally due the woman for the purpose of inflicting mental or emotional anguish upon her.

Evidently, XXX did not willfully refuse to provide financial support for the purpose of inflicting psychological violence upon AAA or her child. Accordingly, the fourth element of the crime was not successfully established. The Court underscores anew a cardinal rule in criminal cases that the prosecution bears the burden of proving each element of the crime beyond reasonable doubt. The conviction must rely on the strength of the prosecution's evidence, rather than the weakness of the defense. Otherwise, any doubt shall be resolved in favor of the accused.

Here, the prosecution was unable to successfully establish that support is legally due AAA and her child and that XXX deliberately withheld the same. Absent the second and fourth elements of Section 5(i) of Republic Act No. 9262, XXX should be exculpated from liability.

Navigating complex domestic issues requires competent legal guidance rooted in the latest developments in Philippine jurisprudence. If you need a lawyer in Tarlac, Pampanga, or nearby provinces to handle cases involving VAWC, family disputes, women and children's rights, or financial support, Cunanan Law Office is ready to protect your interests.

Reach out to our team today to schedule a legal consultation at Cunanan Law Office, Unit 10, Mr. Blue Building, MacArthur Highway, Brgy. Sto. Domingo 2nd, Capas, 2315 Tarlac, Philippines. You can also contact us by phone at +63 968 679 6617, via email at inquiries@mpeclaw.com, or visit our website at www.mpeclaw.com.