In De Guzman v. Perez, the Supreme Court addressed the extent of a parent’s responsibility to provide for their child’s education, specifically when financial means are available. The Court ruled that a parent’s failure to provide education, if their financial condition permits, constitutes neglect under Article 59(4) of PD 603, the Child and Youth Welfare Code. This decision emphasizes the paramount importance of a child’s welfare, reinforcing the principle that parents cannot evade their duty by citing the other parent’s fulfillment of their own responsibilities. It sets a firm precedent that a parent’s financial capability and societal status are key factors in determining their obligation to ensure their child receives an appropriate education.

Neglect or Responsibility? A Father’s Duty to Educate His Child

The case originated from a criminal complaint filed by Shirley Aberde against Roberto de Guzman, the father of her child, Robby. Aberde accused De Guzman of neglecting their child by failing to provide financial support for his education, despite De Guzman’s evident wealth and high social standing. The core legal question was whether De Guzman’s failure to support Robby’s education constituted neglect under Article 59(4) of PD 603, warranting criminal liability.

De Guzman argued that he lacked the financial capacity to provide support and that Aberde was already providing the necessary education. He further contended that neglect could only be established if both parents failed in their duty. The City Prosecutor found probable cause for neglect but dismissed the abandonment charge, leading to a petition for review that eventually reached the Supreme Court. The Secretary of Justice affirmed the City Prosecutor’s resolution, emphasizing De Guzman’s luxurious lifestyle as evidence of his financial capacity and the absence of any contribution to his son’s education. This decision prompted De Guzman to file a petition for certiorari, questioning the findings.

The Supreme Court’s decision centered on whether the Secretary of Justice acted with grave abuse of discretion in sustaining the City Prosecutor’s resolution. The Court clarified that its role was not to substitute its judgment but to determine if the executive branch’s decision was made with grave abuse of discretion, meaning a capricious or whimsical exercise of judgment amounting to an excess or lack of jurisdiction. Citing the legal provisions under scrutiny, the Court highlighted the critical elements constituting child neglect as outlined in Article 59(4) of PD 603, focusing on whether a parent neglects to provide education to a child despite having the financial means and social standing to do so.

Art. 59. Crimes. – Criminal liability shall attach to any parent who: … (4) Neglects the child by not giving him the education which the family’s station in life and financial conditions permit.

Analyzing the facts, the Supreme Court noted that De Guzman acknowledged Robby as his son and admitted his limited contributions to his education. The evidence also indicated his financial capacity to support Robby’s education, as demonstrated by his ownership of substantial shares in RNCD Development Corporation. His argument that these shares were owned by his father was considered a factual claim that should be raised during trial.

The Court firmly rejected De Guzman’s contention that both parents must be neglectful for criminal liability to attach. The law clearly states that any parent who neglects a child’s education, given their financial capacity, can be held liable. This interpretation aligns with the principle that the child’s welfare is paramount, preventing neglectful parents from shirking their responsibility by pointing to the other parent’s compliance. The Court elucidated the relationship between Article 59(4) of PD 603 and Section 10(a) of RA 7610, which penalizes acts of neglect not covered by the Revised Penal Code. Since “indifference of parents” under Article 277 of the Revised Penal Code also punishes the failure to provide education, the charge against De Guzman could not be made in relation to RA 7610.

Therefore, while the Court upheld the probable cause for indicting De Guzman under Article 59(4) of PD 603, it clarified that the charge could not be related to Section 10(a) of RA 7610. Crucially, the decision underscored that it was not making a determination of De Guzman’s guilt, as the presumption of innocence remained. The ruling simply confirmed the existence of sufficient grounds to believe a crime had been committed and that De Guzman was probably guilty, necessitating a trial. This case elucidates the critical importance of parental responsibility in ensuring a child’s education and provides clear guidelines on the legal consequences of neglecting that duty.

FAQs

What was the key issue in this case?	The central issue was whether a parent could be held criminally liable for neglecting to provide a child with education, as stipulated under Article 59(4) of PD 603, despite having the financial means to do so.
What is Article 59(4) of PD 603?	Article 59(4) of PD 603, also known as the Child and Youth Welfare Code, specifies that criminal liability attaches to any parent who neglects to give their child the education that their family’s financial conditions and station in life permit.
Can one parent be held liable if the other parent is fulfilling their duties?	Yes, the Supreme Court clarified that the law allows any parent to be held liable for neglect, regardless of whether the other parent is fulfilling their parental duties. This means one parent cannot excuse their neglect by citing the other parent’s actions.
What evidence did the court consider in determining financial capacity?	The court considered the parent’s luxurious lifestyle and the ownership of assets such as shares in a development corporation. These were used as indicators of financial capacity to provide for the child’s education.
What is the difference between PD 603 and RA 7610 in this context?	PD 603, specifically Article 59(4), directly addresses neglect of a child’s education. RA 7610 covers acts of neglect not covered by the Revised Penal Code; since the Revised Penal Code already addresses indifference of parents (Art. 277), RA 7610 does not apply.
What was the final ruling of the Supreme Court?	The Supreme Court dismissed the petition, upholding the Secretary of Justice’s decision to sustain the City Prosecutor’s finding of probable cause for child neglect under Article 59(4) of PD 603.
What should parents do to ensure they are meeting their legal obligations?	Parents should actively contribute to their child’s education, ensuring they receive the best possible schooling that the family’s financial situation allows. Engaging in financial planning and open communication about educational needs is essential.
How does this case affect single parents?	This case reinforces the duty of both parents, whether married or single, to financially support their child’s education, holding them accountable based on their individual capacity to contribute.

This case underscores the judiciary’s commitment to protecting children’s rights and ensuring parental responsibility. By emphasizing the critical role of education in a child’s development and upholding the legal consequences of neglect, the Supreme Court reinforces the message that parents must prioritize their children’s welfare. This ruling serves as a crucial reminder of the shared responsibility of parents to secure the best possible future for their children, within the bounds of their capabilities.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: De Guzman v. Perez, G.R. No. 156013, July 25, 2006