GO TAN VS SPS PERFECTO AND JUANITA TAN, 567 SCRA 231, SEP 30, 2008

Facts: Steven & Sharica are husband and wife. They have two female children. Sharica alleged that Steven, in conspiracy with his parents, provided her with insufficient financial support, harrased and pressured her to be ejected from the family home and repeteadly and verbally abused her which caused her psychological and economic abuses upon her. Respondent contended that, as parents in-law of Sharica, they are not covered by R.A. 9262

Issue: Whether or not the parents-in-law are correct?

Rule: The definition of in section 3 of RA 9262 does not preclude the application of the principle of conspiracy under the RPC. For section 47 of the act provides suppletory application. But even the absence of section 47, Art. 10 of the RPC mandates that the latter shall be supplementary to special laws. With more reason, therefore, the pricnciple of conspiracy under Art.8 of the RPC may be applied to the said act. The Supreme Court, through Former Justice and our Beloved Dean AUSTRIAMARTINEZ, ruled that the parents-in-law are covered by the Republic Act 9262.