MANILA — The Supreme Court of the Philippines has acquitted a man previously convicted under the Anti-Violence Against Women and Their Children (VAWC) Act for allegedly refusing to provide financial support to a child whose paternity was not established.

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

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

The accused denied being the father of the child, arguing that the child was born only eight months after their last sexual encounter.

According to the court, both parties discussed undergoing DNA testing to determine paternity, but no examination was conducted after they failed to agree on who would shoulder the cost.

During trial, the woman submitted the child’s birth certificate as evidence. However, the section identifying the father was marked “N/A” and remained unsigned.

The woman also admitted in court that the accused refused to provide financial support because he doubted he was the child’s father.

The RTC convicted the accused after giving greater weight to the woman’s testimony over his denial, while the CA later upheld the ruling, stating that proof of paternity was not an essential element of the offense.

The Supreme Court, however, ruled that a conviction for economic abuse under Section 5(i) of Republic Act 9262 requires proof that the victim is a woman and/or her child, that the woman is the offender’s spouse or partner or someone with whom he has a common child, that the offender refused to provide financial support due, and that the refusal was intended to inflict mental or emotional suffering.

In this case, the SC found that the prosecution failed to establish that the accused and the complainant shared a common child, as well as failed to prove that the refusal to provide support was meant to cause psychological harm.

The high court stressed that the legal obligation to provide support only arises after filiation or paternity has been established.

It also said that when a birth certificate is used as proof of filiation, it must bear the signatures of both the mother and the father.

“Because the accused’s paternity was not proven in this case, no legal obligation to provide support could be imposed,” the SC said in a news release.

The tribunal further ruled that even if paternity had been proven, criminal liability would still require evidence showing that the accused intentionally withheld support to cause suffering to the woman, “which was not proved in this case.”