Facts:
Rosalie Jaype-Garcia (private respondent) married Jesus C. Garcia (petitioner) in 2002, a relationship that bore three children. The couple’s marital union was marred by petitioner’s infidelity, physical, emotional, psychological, and economic violence which prompted private respondent to file a verified petition for the issuance of a Temporary Protection Order (TPO) on March 23, 2006 before the Regional Trial Court (RTC) of Bacolod City pursuant to Republic Act (R.A.) No. 9262, known as the “Anti-Violence Against Women and Their Children Act of 2004”.
The petitioner admitted his extramarital affairs, exerted controlling behavior, and perpetrated physical and emotional abuse against the private respondent and their children. The abuse escalated to the point that the private respondent attempted suicide. Petitioner exercises domination over family businesses while denying adequate financial support to his family. The trial court issued several TPOs, granting various reliefs and extending protection for the private respondent and her children.
Following these developments, the petitioner filed a petition for prohibition with the Court of Appeals (CA), challenging the constitutionality of R.A. 9262, alleging violation of the equal protection and due process clauses, and an undue delegation of judicial power to barangay officials. The CA dismissed the petition, ruling that the issue of constitutionality was not raised in the trial court and the challenge constitutes a collateral attack on the validity of the law.
Issues:
1. Whether the petition for prohibition was the proper remedy to assail the constitutionality of R.A. 9262.
2. Whether R.A. 9262 violates the equal protection clause.
3. Whether R.A. 9262 infringes upon the due process clause.
4. Whether R.A. 9262 undermines the policy of the State to protect the family as a basic social institution.
5. Whether R.A. 9262 permits an undue delegation of judicial power to barangay officials.
Court’s Decision:
1. The Court affirmed the CA’s dismissal, holding that the constitutionality of a law should be challenged at the earliest opportunity, and that a petition for prohibition is an inappropriate vehicle for challenging an interlocutory order, in this case, the TPO, in the RTC proceedings.
2. The Supreme Court upheld the constitutionality of R.A. 9262, ruling that the law’s classification was not arbitrary or discriminatory as it was based on substantial distinctions between the experiences of men and women concerning domestic violence.
3. The Court found that R.A. 9262 does not violate the due process clause, providing safeguards such as immediate notice and hearing following the issuance of TPO ex parte, ensuring balance between the need for prompt action in VAWC cases and procedural fairness to the respondents.
4. The Court held that R.A. 9262 does not undermine the family’s integrity; rather, it seeks to strengthen and protect the family by addressing the prevalence of domestic violence, which threatens the safety and welfare of family members.
5. In its ruling, the Court stated that the issuance of Barangay Protection Orders (BPOs) by barangay officials is an executive function, not judicial, and within the parameters set by R.A. 9262 – thus not constituting an undue delegation of judicial power.
Doctrine:
The Supreme Court upheld the constitutionality of R.A. 9262, ruling that the law does not infringe upon the equal protection and due process clauses of the Constitution and does not unduly delegate judicial power. The Court held that immediate protection is warranted under the law to prevent further violence against victims and that the law is substantial in differentiating the experiences of women from men in domestic violence scenarios. BPOs issued by barangay officials are considered an extension of executive, not judicial, functions, enacting the legislative intent to address domestic violence expeditiously.
Class Notes:
– Equal Protection Clause: A law must be based on a reasonable, substantial distinction to be constitutionally valid and serve a legitimate government objective.
– Due Process Clause: In cases where life, liberty, or property interests are at stake, procedural fairness must be observed, including notice and opportunity to be heard.
– Delegation of Power: Delegation is permissible if it falls within a statutory framework that provides sufficient standards and limitations to guide the delegate.
Historical Background:
R.A. 9262 is a result of advocacy efforts to combat violence against Filipino women, reflecting international commitments under human rights instruments such as the CEDAW. The law illustrates the evolving societal and legal stance against domestic violence and emphasizes the State’s role in protecting vulnerable members of the family unit.
Leave a Reply