Dabalos vs RTC

Facts of the Case:

Relationship ended prior the incident
The complainant demanded for payment of debt
of respondent.
Respondent slapped her, pulled her hair, punched
the complainants back, shoulder and left eye,
 Petitioner contends that
RA 9262 is no longer applicable since their
relationship already ceased prior the incident
physical injuries inflicted to private respondent is
not covered by RA 9262 because its proximate
cause was not their dating relationship
 Court ruled that:
it is not indispensable that the act of violence be a
consequence of such relationship. Nowhere in the
law can such limitation be inferred.
 any act or series of acts to be considered as a
crime of violence
It is committed against a woman or her child and
the woman is the offenders wife, former wife, or
with whom he has or had a sexual or dating
relationship or with whom he has a common
child;
It results in or is likely to result in physical harm or
suffering.
 Court also ruled that:
it is immaterial whether the relationship had
ceased for as long as there is sufficient evidence
showing the past or present existence of such
relationship between the offender and the victim
when the physical harm was committed.
 Ang vs Court of Appeals
Facts of the case:
Irish Sagud and Rustan Ang became "on-and-off"
sweethearts.
Irish received through multimedia message
service (MMS) a picture of a naked woman with
her face superimposed on the figure.
He threatened to spread the picture through the
internet.
Under police supervision, she contacted Rustan
and asked him to meet her at a resort.
 Issues of the case:
WON there is a dating relationship existed under
Section 3(a) of RA 9262
WON a single act of harassment, like the sending
of the nude picture in this case, already
constitutes a violation of Section 5(h) of R.A.
9262.
 Court held that:
Yes, the dating relationship that the law
contemplates can, therefore, exist even without a
sexual intercourse taking place between those
involved.
An "awaybati" or a fightandkiss thing between
two lovers does not mean that the romantic
relation between the two should be deemed
broken up during periods of misunderstanding.
 The case illustrates the elements of the crime
of violence against women through
harassment which are:
The offender has or had a sexual or dating
relationship with the offended woman;
The offender, by himself or through another,
commits an act or series of acts of harassment
against the woman; and
The harassment alarms or causes substantial
emotional or psychological distress to her.
 The court also ruled that:
YES. Section 3(a) of R.A. 9262 punishes "any act or
series of acts" that constitutes violence against
women.