* the case is rly short hehe*

DABALOS v. RTC (2013)

 Petitioner charged with violations of Sec 5 (a) of VAWC [Causing physical
harm to the woman or her child] in RTC Angeles City, BR 59
 INFO → JUL 13, 2009 He was boyfriend of complainant, and allegedly
pulled her hair; punched her back, shoulder and left eye
 RTC found probable cause and issued a warrant of arrest Nov 19 2009→ he
posted bail on Aug 12 2010
 PETITIONER avers that he was no longer in dating relationship with private
respondent, thus VAWC cannot apply
 VICTIM admitted that the relationship had ended prior to JUL 13, 2009 ;
that she sought payment from DABALOS (because she had previously lent
him money) but he refused to pay ; she inquired if DABALOS had been the
one spreading rumors about her, which he ADMITTED → VICTIM slapped
DABALOS because of this, and he retaliated by inflicting aforementioned
injuries
 RTC RULING: Denied motion → It did not consider as material the fact that
the relationship had ended; that it previously existed coupled with the
infliction of injuries constituted a crime under VAWC
 Raised on appeal → Special civil action & prohibition
 SC RULING: NO MERIT; CASE DISMISSED
 DABALOS insists that the crime is not covered by VAWC because its
proximate cause was not their dating relationship; He claims that it was
only slight physical injuries under RPC
 While it is a requirement that the offender HAS/HAD a sexual or dating
relationship with the offended woman in order for RA 9262 to be
applicable, IT IS NOT INDISPENSABLE that the act of violence must be a
consequence of such relationship
 → Clearly, punishable acts refer to ALL ACTS OF VIOLENCE agianst
women with whom the offender HAS/HAD a sexual or dating relationship
 The court cannot construe VAWC in favor of petitioner in lieu of the rule
of lenity, because it is not ambiguous; CLEARLY, the legislative intent is
to impose a more severe punishment on offenders who commit violence
upon women they have/had a sexual/dating relationship with
 The INFORMATION likewise sufficiently alleged the necessary elements →
That there was a dating relationship → That the were acts of violence
committed by petitioner → That the resulting physical harm to victim, is
also covered by VAWC
 That the TRIAL court allowed the information to be amended in order to
include the cessation of the relationship (which was the subject of
DABALOS' Motion to Quash) is in accordance with Rule 117