Published 17 April 2023, The Daily Tribune

The Court further explained that Section 5 of the Anti-VAWC Law expressly recognizes that the acts of violence against women and their children may be committed by an offender through another, thus:

Sec. 5. Acts of Violence Against Women and Their Children — The crime of violence against women and their children is committed through any of the following acts:

(h) Engaging in purposeful, knowing, or reckless conduct, personally or through another, that alarms or causes substantial emotional or psychological distress to the woman or her child. This shall include, but not be limited to, the following acts:

(1) Stalking or following the woman or her child in public or private places;

(2) Peering in the window or lingering outside the residence of the woman or her child;

(3) Entering or remaining in the dwelling or on the property of the woman or her child against her/his will;

(4) Destroying the property and personal belongings or inflicting harm to animals or pets of the woman or her child; and

(5) Engaging in any form of harassment or violence.

The Supreme Court added that the protection order that may be issued to prevent further acts of violence against the woman or her child may include individuals other than the offending husband, thus:

Sec. 8. Protection Orders — The protection orders that may be issued under this Act shall include any, some, or all of the following reliefs:

(a) Prohibition of the respondent from threatening to commit or committing, personally or through another, any of the acts mentioned in Section 5 of this Act;

(b) Prohibition of the respondent from harassing, annoying, telephoning, contacting, or otherwise communicating with the petitioner, directly or indirectly.

Finally, Section 4 of RA 9262 calls for a liberal construction of the law to promote the protection and safety of victims of violence against women and their children.

From the foregoing ruling that deemed that the principle of conspiracy may be applied suppletorily to RA 9262, it cannot be denied that not only parents-in-law may be held liable, but any person/persons who share a common and purposeful design with a perpetrator who commits violence against “a woman who is his wife, former wife, or against a woman with whom the person has or had a sexual or dating relationship, or with whom he has a common child.”

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