SC acquits man in VAWC case: No paternity proof, no economic abuse

The Supreme Court (SC) has acquitted a man previously convicted of economic abuse under the country’s anti-violence law, ruling that paternity must first be clearly established before a person can be held criminally liable for failing to provide child support.

In a decision penned by Associate Justice Japar Dimaampao, the High Court’s Third Division reversed earlier rulings of the Regional Trial Court and the Court of Appeals, which had found the accused guilty under Republic Act 9262.

The case stemmed from a complaint filed by a woman against her former partner, accusing him of refusing to provide financial support for her child. 

The man, however, consistently denied paternity, pointing out that the child was born eight months after their last sexual encounter. 

While both parties had discussed DNA testing to resolve 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 the portion identifying the father was left blank and unsigned. 

The woman also testified that the accused withheld support because he doubted he was the father.

Despite this, the trial court convicted the man, giving greater weight to the woman’s account. 

The appellate court affirmed the ruling, holding that proof of paternity was not required to establish economic abuse.

The Supreme Court disagreed.

It clarified that for a conviction under Section 5(i) of the Anti-VAWC Act, prosecutors must prove not only that financial support was withheld, but also that a legal obligation to provide such support exists, a duty that arises only after paternity or filiation has been established.

In this case, the SC found that the prosecution failed to prove two key elements: that the accused and the complainant shared a common child, and that the alleged refusal to provide support was intended to cause psychological or emotional harm.

The tribunal emphasized that a birth certificate alone cannot establish paternity unless it is properly signed by both parents. Without proof of filiation, the High Court said, no enforceable obligation of support can be imposed.

It added that even if paternity had been proven, criminal liability would still require clear evidence that the accused deliberately withheld support to inflict suffering—a condition not met in this case.