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The Continuing Challenge of Implementing the BPO Provisions of RA

92621 SALIGAN Women’s Program2

INTRODUCTION

The importance of Republic Act No. 9262 (RA 9262) or the Anti-Violence Against

Women and their Children (Anti-VAWC) Act is not merely that it etched a much-needed

policy in law. RA 9262 is significant because it provided a conceptual framework based on

which domestic violence, one of the most common violations committed against women in

the Philippines, may be responded to by all sectors of society. More than being a legal

document, it lays down and promotes a real understanding of the nature of violence against

women.

Five years after its celebrated passage3, a serious and perceptive evaluation of the

implementation of this significant piece of gender legislation is in order. In doing so, it is

imperative that prevailing mindsets of concerned actors be considered. It is not enough to

ask whether anti-VAWC cases were filed and won. It is doubly important to know if a

greater part of society has grasped a deep enough understanding of violence against

women that will finally give way to its elimination. This is clearly not an easy task.

Following the track of monitoring and evaluating the state of implementation of RA 9262,

an ideal one to take on the law’s fifth year of effectivity, SALIGAN has chosen to study an

aspect of the law that is closest to the household or domestic sphere.

A key provision of RA 9262 is making available a Barangay Protection Order (BPO)

to guard a violated woman from further physical harm. Authorizing villages or

"barangays," the country’s smallest local government unit (LGU), to issue and enforce BPOs

is a source of relief that is speedy and readily accessible. For this study, SALIGAN

communicated with barangay officials in order to assess how effectively the BPO provision

of RA 9262 has been implemented. A simple data-gathering tool4 was developed and

distributed among sample barangays in Luzon, Visayas and Mindanao not only to gather

1 Republic Act 9262 or the Anti-Violence Against Women and Their Children Act is discussed in detail under the Legal Framework section of this paper. 2 SALIGAN (Sentro ng Alternatibong Lingap Panligal) is a non-governmental organization doing developmental legal work with farmers and fishers, workers, the urban poor, workers, and local communities. 3 This research was first conducted in 2008 and completed in 2009. 4 Attached as Annex A.”

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statistics, but also to gain first-hand knowledge of how barangay officials view domestic

violence and how they have made use of their legal powers to actually curb it.

A special difficulty in monitoring and evaluating BPO implementation is brought

about by the utter lack of organized data on either national or local levels. Unless a

nationwide data-gathering campaign is launched, one will have to rely on modest efforts by

non-government organizations (NGOs) such as SALIGAN to gather details from individual

barangays. Though limited in scope, our data-gathering device is, at this point, the only way

of collecting relevant quantitative and qualitative data for evaluation and monitoring

purposes. For now, it sufficiently meets the following objectives: 1) to develop an

appreciation of the level of understanding of barangay officials on existing policy and

legislation on VAWC; 2) to document experiences of barangays in implementing the BPO

provision of RA 9262; 3) to point out barangays’ areas of weakness in terms of BPO

implementation and determining their actual needs in relation to these; and 4) to identify

the necessary executive, legislative and judicial actions that will lead to a satisfactory

implementation of the BPO provision of RA 9262.

To supplement our data gathered from sample barangays, we will also present

relevant information from actual cases we encountered through many legal consultation

sessions, from 2004 up to the present.

The underlying goal of this study is to communicate the prevailing variance between

policy and action on the BPO provision of RA 9262. It seeks to provide an illustration of

how barangays fared in implementing their responsibilities under the law. While the

research does not attempt to paint a comprehensive assessment of access to barangay

protection orders in the entire country, it seeks to highlight, albeit in a limited capacity,

how far barangays have come in fulfilling their mandate under the law nearly five years

after its enactment.

As an NGO dealing with advocacy, education, and litigation, SALIGAN is in a unique

and crucial position to share its insight on how the law came to be, how it is supposed to be

implemented, and how its implementation is being carried out. This has allowed the

organization to collaborate with many helpful NGOs, people’s organizations and

government offices in the gathering of barangay data. This study is a product of such

diverse experiences and meaningful collaborations.

SCOPE, LIMITATION, and METHODOLOGY

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The novelty of the remedies provided in RA 9262 created multiple legal challenges

for institutions mandated to implement the law. The barangay is no exception. Problems

related to the issuance of BPOs are among those commonly brought to SALIGAN for legal

consultation. To examine this situation more closely, SALIGAN conducted surveys in

different barangays regarding their delivery of services under RA 9262. Queries on the

issuance of BPOs encountered through legal consultations were likewise gathered and are

presented in this paper.

Survey of Barangay Cases

Survey forms were distributed to four focus areas: Naga, Manila, Dumaguete and

Davao. Identified areas were chosen based on their geographic location and on the

presence of partner organizations therein. The survey in Davao City was coursed through

SALIGAN’s office in Davao and its partner, the Integrated Gender Development Division of

the City Government of Davao. That in Dumaguete was made possible through Gender

Watch Against Violence and Exploitation (GWAVE), another partner organization. In Naga,

the survey was conducted by SALIGAN’s Bicol office, and finally, the local government of

Manila contributed survey results from barangays within the city.

A total of 97 barangays responded to the survey, with the following breakdown: 34

barangays out of 182 barangays in Davao City; 15 out of 27 barangays in Naga City; 28 out

of 30 barangays in Dumaguete City; and 39 out of 897 barangays in the City of Manila.

While the number of respondents may be small, especially in comparison to the 41,995

total number of barangays in the country, the sample provides a fair illustration of how

barangay officials carry out their functions as mandated by RA 9262.

Barangays were asked to answer the survey based on their own experiences as

regards the handling of BPO cases. As some officials were newly elected, certain answers

were limited to their term starting 2007. Survey questions covered the number of BPO

cases accommodated by the barangay since 2004; grounds cited in BPO applications as well

as in the denial and dismissal of these cases; time elapsed between a BPO application and

its issuance and/or renewal; other services provided by the barangay as mandated by RA

9262; and knowledge and skills of barangay officials on the law.

Survey of SALIGAN Cases

Since the enactment of RA 9262 in 2004, SALIGAN has been active in advancing the

law especially through the litigation of “test cases.” In some of the case consultations

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handled, clients presented issues concerning the implementation of the law at the barangay

level, with respect in particular to the issuance of BPOs. Data from these consultations are

presented in this research to illustrate common problems encountered by women seeking

assistance from the barangay.

The case consultations presented cover those conducted from 2004 to 2008. During

this time SALIGAN handled 132 consultations involving RA 9262, 25 of which gave rise to

issues about barangay protection orders. The barangays involved in these consultations are

mostly located in Metro Manila, as clients who come in for consultation with us are often

Metro Manila residents.

LEGAL FRAMEWORK

The existence of the barangay protection order as a remedy is deeply and strongly

anchored on both international covenants, which the Philippines has acceded to or ratified,

and on our own local laws and legal systems.

International Agreements

The Philippines has, over many decades, given and repeatedly confirmed its assent

to international documents and treatises establishing the protection, promotion and

fulfillment of the right of women to live free from discrimination, inequality and violence

against their person. Foremost of these is its commitment as a member of the United

Nations, whose charter is the first international instrument to uphold the equal rights of

men and women, along with other human rights and fundamental freedoms.

The Universal Declaration of Human Rights afterwards echoed this provision, stating

in its preamble that “the peoples of the United Nations have in the Charter reaffirmed their

faith in fundamental human rights, in the dignity and worth of the human person and in the

equal rights of men and women and have determined to promote social progress and

better standards of life in larger freedom.”

Later, the Declaration on the Elimination of Violence Against Women recognized

violence as rooted in historical power inequalities between men and women, while

elucidating that VAW violates existing universal human rights norms. It also gave an

expansive definition of violence and emphasized the State obligation to ensure prevention,

investigation and punishment of perpetrators.

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Aside from espousing these proclamations, the Philippines has also legally bound

itself to carry out their provisions, by signing the International Covenants on Economic,

Social and Cultural Rights, and on Civil and Political Rights. These unequivocally state that

the rights provided therein are applicable to all persons without distinction of any kind,

and lay down sex as such a ground of impermissible distinction. Both impose on acceding

or ratifying States the undertaking to ensure that women and men have equal right to the

enjoyment of all the rights they establish.

Despite these acts institutionalizing the denouncement of discrimination against

women around the world, they were still found lacking as there remained no recognition of

women’s human rights in mainstream human rights discourse, proclamations and

practices. Priority was placed on international political rights rather than civil and political

rights, while the violation of women’s rights usually occurred within socio-economic

spheres. Nevertheless, these acts paved the way towards the creation of a legal document

that focuses specifically on women’s rights and freedoms, what constitute violations

against them, and how they may be remedied.

CEDAW

The Convention on the Elimination of All Forms of Discrimination Against Women

(CEDAW) is often referred to as the “international bill of rights on women.” The Convention

is a milestone in the advancement of women’s rights at the international and local spheres

because of its two most important provisions: the definition of “discrimination against

women,” and the principle of State obligation to women.

Having become effective in 1981, the CEDAW is the sole international legal

instrument specifically designed to promote and protect women. It defines discrimination

against women as “any distinction, exclusion or restriction made on the basis of sex which

has the effect or purpose of impairing or nullifying the recognition, enjoyment or exercise

by women, irrespective of their marital status, on a basis of equality of men and women, of

human rights and fundamental freedoms in the political, economic, social, cultural, civil or

any other field” (Article 1). This provision was crucial in promoting gender equality across

States because it gave specific grounds on which punishment for discrimination may be

based. It also provided a broad and encompassing definition, ensuring that the many and

varying forms of discrimination can be covered and made punishable within States which

ratified the Convention, without having to be enumerated.

Moreover, the Convention made it an obligation of State parties, among which is the

Philippines, to:

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1. Enshrine the principle of gender equality in national constitutions and legal

systems;

2. Abolish all discriminatory legislations and adopt those that promote and protect

women’s rights; and

3. Establish tribunals and other public institutions to give legal effect to women’s

rights.

Of the country’s manifold covenants where it compels itself to eradicate all forms of

discrimination against women within its borders, these restrictions under the CEDAW

remain the strongest basis against which to evaluate the State’s compliance with its

obligations.

1987 Philippine Constitution

Although the Philippines has a long way to go in terms of fully achieving gender

equality in its systems, institutions and legal processes, it has made steps toward such in

concrete ways, most notably by incorporating its duty under the CEDAW into the 1987

Constitution.

Article II, Section 14 of our fundamental law states that “[t]he State shall recognize

the role of women in nation-building, and shall ensure the fundamental equality before the

law of women and men.” Likewise being very broadly stated, it has given Congress much

leeway in crafting laws that address specific women’s issues in our country, particularly

with regard to violence against themselves and/or their children. A wide range of laws

have been enacted by the legislature since the establishment of our present Constitution,

such as RA 9262, RA 9208 (Anti-Trafficking in Persons Act), RA 8353 (Anti-Rape Act), and

RA 7877 (Anti-Sexual Harassment Act), among others.

RA 9262

RA 9262 or the Anti-VAWC Act, enacted only fairly recently in 2004, specifically

focuses on the elimination of violence against women. At the time of its enactment and up

to the present, the reliefs given under the law to women in abusive relationships have

proved critical in enabling them to seek recourse against persons causing or committing

acts of violence against them, and in helping them take significant steps toward self-

determination.

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The Anti-VAWC Act was progressive in that it concretely identified the forms of and

acts which consist in violence against women and their children; who may be considered

perpetrators of violence; the sanctions that may be imposed on violators of prohibited acts;

and the civil and criminal remedies to which victims are entitled.

Among these remedies is the filing of a petition for a protection order with the court

or barangay in the place where the petitioner resides or is located, through which women

and/or their children, who were or are victims of any acts or omissions prohibited under

the law, may seek relief against the perpetrator. The law defines a protection order as one

issued to prevent further acts of violence against a woman and/or her child, and to grant

other necessary relief. Its purpose is to safeguard the victim from further harm, minimize

any disruption in the victim’s life, and facilitate the opportunity and ability of the victim to

independently regain control over her life (Section 8). If filed with the court, a temporary or

permanent protection order (TPO or PPO, respectively) may be issued.

In conjunction with or independently of this court-issued protection order, the

victim or other interested persons enumerated in the law may also file an application for a

protection order in the barangay. RA 9262 sets forth the definition of a BPO, the reliefs it

may grant, the procedure necessary for its issuance, its effectivity and enforceability,

sanctions for its violations, as well as the duties and responsibilities of barangay officials

and other law enforcers in its implementation. BPOs primarily enable battered/abused

women, who have limited or no access to Courts, to gain protection from further abuse

through their own barangays.

As the smallest political unit in the country, the barangay is unique and distinct

compared to other local government bodies. Because it is rooted in the community, it is

considered apolitical. Also, because its officials are considered to have moral ascendancy in

the community, they are conferred with an informal authority to settle community

disputes. Because of the barangay’s proximity to the community, it is able to immediately

address and give assistance to its constituents. For these reasons, RA 9262 confers on

them a distinct role in the elimination of domestic violence, or abuse of women in intimate

relationships, at the level of the LGU.

Local Government Code

RA 9262 recognizes the strategic position of the barangay as a local government

unit in playing a key role in the elimination of domestic violence. However, the duty and

responsibility of a barangay to intervene in situations of VAW find authority not only in the

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Anti-VAWC law, but also in RA 7160 or the Local Government Code of the Philippines (LGC),

the main source of the LGU’s powers and functions. Section 384 of the LGC provides thus:

Role of the Barangay. - As the basic political unit, the barangay serves as the primary

planning and implementing unit of government policies, plans, programs, projects,

and activities in the community, and as a forum wherein the collective views of the

people may be expressed, crystallized and considered, and where disputes may be

amicably settled. (Emphasis supplied)

Indeed, the barangay has both the authority and capacity to most immediately

respond to situations of violence within its territorial jurisdiction. It is in the best position

to extend aid to victims of VAW, from providing emergency response to the household to

the establishment of centers where victims may seek shelter, among many other possible

forms of assistance.

Under RA 9262, it is the Punong Barangay that has the power to receive applications

for BPO and to issue such if s/he finds that there is basis for it. Her/his functions under the

LGC likewise authorize her/him to perform these functions, under the following provisions:

Section 389. Chief Executive: Powers, Duties, and Functions. - (a) The punong

barangay, as the chief executive of the barangay government, shall exercise such

powers and perform such duties and functions, as provided by this Code and other

laws.

(b) For efficient, effective and economical governance, the purpose of which is the

general welfare of the barangay and its inhabitants pursuant to Section 16 of this

Code, the punong barangay shall:

(1) Enforce all laws and ordinances which are applicable within the

barangay;

xxx

(3) Maintain public order in the barangay and, in pursuance thereof, assist

the city or municipal mayor and the sanggunian members in the performance

of their duties and functions;

xxx

(14) Promote the general welfare of the barangay; and

(15) Exercise such other powers and perform such other duties and

functions as may be prescribed by law or ordinance.

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The powers and duties of the Sangguniang Barangay in implementing the BPO

provisions of RA 9262, on the other hand, find support in the following LGC provisions

detailing their general powers as local government officials:

SEC. 391. Powers, Duties, and Functions. - (a) The sangguniang barangay, as the

legislative body of the barangay, shall:

xxx

(16) Provide for the organization of community brigades, barangay tanod, or

community service units as may be necessary;

xxx

(19) Provide for the proper development and welfare of children in the

barangay by promoting and supporting activities for the protection and total

development of children, particularly those below seven (7) years of age;

(20) Adopt measures towards the prevention and eradication of drug abuse,

child abuse, and juvenile delinquency;

xxx

(23) Provide for the delivery of basic services; and

(24) Exercise such other powers and perform such other duties and

functions as may be prescribed by law or ordinance.

SEC. 392. Other Duties of Sangguniang Barangay Members. - In addition to their

duties as members of the sangguniang barangay, sangguniang barangay members

may:

(a) Assist the punong barangay in the discharge of his duties and functions;

(b) Act as peace officers in the maintenance of public order and safety;

xxx

The legal bases elucidated provide a concrete framework for the present analysis.

With the above policies as a backdrop, an appropriate assessment may be carried out of

how the Philippines has fared in discharging its international obligations to ensure the

equal rights of men and women, and in implementing its own laws designed to achieve the

same purpose.

SUMMARY OF FINDINGS

Data from Barangay Surveys

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A total of ninety-seven (97) barangays responded to the survey questionnaire

distributed by SALIGAN’s partner organizations among barangays in key cities in Luzon,

Visayas, Mindanao and the Bicol region. Of these, thirty-nine (39) respondents are from

Manila, fifteen (15) from Naga, fifteen (15) from Dumaguete, and twenty-eight (28) from

Davao. These 97 barangays comprise the sample population of this survey.

45% of the BPO applications surveyed was filed by wives who are legally married to

the respondents, while 26% was filed by unmarried women against their romantic

partners. 22% was filed by women in live-in or common-law relationships, and 7% by

women in the dating stage or those who are in the earlier stages of romantic relationships,

as distinguished from unmarried romantic partners.

The survey reveals remarkable results on the modes by which applications for

barangay protection orders are turned down or disapproved. For every dismissal based on

an actual examination of the merits of the case, two are dismissed on the basis of

reconciliation or amicable settlement. In other words, almost 67% of all incidences where

BPO applications are not granted is based on the reconciliation or amicable settlement of

the parties involved.

In the validation workshop held in Davao City, the participants were asked about

how the amicable settlement of BPO applications comes about. According to the

participants, the parties would usually just settle the case among themselves. Despite

showing a high level of awareness of BPOs in urban barangays in Naga, couples resort to

traditional modes of dispute resolution, such as consulting with family members and in-

laws to appease the situation and help the couple resolve their differences.

In Davao, the participating barangay officials displayed awareness of the rule that

they should not intervene in settling the case. They claimed that at times, they are not even

informed of the reconciliation. Some officials view this phenomenon negatively because it

gives them the sense that barangay processes are being misused. In the Naga and Quezon

City validation sessions, however, it was revealed that barangay officials at times become

personally involved in the dispute, and are thus not impartial mediators. A participant in

Naga revealed that barangay officials would sometimes induce the aggrieved party to make

peace with her husband in order to preserve the family. In Quezon City, a barangay official

lectured the abused woman on religion and the duty of the couple to maintain the

cohesiveness of the family.

A participant in the Davao validation workshop cited that 90-95% of VAWC cases

brought before her barangay is amicably settled. Another recounted that it was usual for

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women to be keen on reporting and requesting for a BPO one to three days after the VAWC

incident. On the fourth or fifth day however, she would become reluctant to pursue the

complaint. This was attributed to the observation that women have the tendency to feel

pity for their husbands or partners once a complaint is filed. Some are suddenly stricken

with fear. Most eventually realize their lack of capacity to pursue the complaint because of

their financial dependence on their husbands or partners. These observations came out in

the Naga and Quezon City workshops, a participant in Naga affirming that it was not

unusual for the complainant to have already reconciled with her partner even before the

expiration of the 15-day BPO and thus refusing to pursue the complaint. It also reportedly

happens that complainants seek the issuance of BPOs for the specific purpose of reconciling

with their husbands instead of seeking legal relief from abuse they experienced.

Other grounds cited for the denial of BPO applications include the eventual lack of

interest of the complainant, the lack of jurisdiction of the barangay, and the non-

appearance of the parties before the barangay. Some respondents added that complainants

eventually lose interest in the case or fail to appear before the barangay because of fear of

the husband, a very sensitive regard for the possible effect of case-filing on their children,

financial difficulties, the lack of confidence in pursuing a case, and the lack of knowledge of

the law. In Quezon City, absence of separate rooms in conducting investigations is also a

factor why few BPOs are pursued. Because they are exposed to the public and their issues

are revealed to an audience not party to the case, victims become too ashamed to press on

with the complaint.

23% of the barangay respondents surveyed has at one point or another assisted

victim-survivors in the filing of court cases for the issuance of Permanent Protection

Orders. The remaining 77% has not. Most of the reasons cited for their inaction are also

those commonly behind the denial of BPO applications: reconciliation, amicable settlement,

the non-appearance of parties, lack of interest on the part of complainants, lack of financial

capacity, and the eventual hesitation of complainants to get involved in full-blown court

cases. One barangay in Manila stated that they abstain from giving such assistance in order

to maintain barangay neutrality. A barangay in Davao said that instead of assisting in the

actual filing of cases, they instruct the complainants on the proper procedure for case-filing

in court and the documents needed for such.

The workshops showed that BPOs were sometimes used by applicants for purposes

other than those intended by the law. The palpable reason for this is their impression that

BPOS provide immediate relief from any kind of domestic problem, including issues which

are in reality beyond its scope. In one instance, a complainant in Naga sought for a BPO to

get support from her erring husband instead of filing a civil case in court. There were also

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incidents when complainants asked for BPOs to stop the illicit affairs of their husbands, and

even cases where it was the male partner who applied for a BPO.

The survey also tackled the length of time in which barangays deliberated whether

to grant or deny BPO applications. Findings show that barangays take an average of five (5)

days to rule on BPO applications. The longest processing period is seven (7) days. In spite

of this outcome, the participants in the Davao validation noted that they are aware of the

need to issue BPOs within twenty-four (24) hours after application.

When asked whether or not they renewed BPOs, 35% of the barangays answered

positively while 65% answered in the negative. The differing views among barangay

officials on the renewability of BPOs was apparent in the validation workshops. Some

participants shared that they had attended trainings where they were informed that BPOs

are not renewable. Other participants ratiocinated that even if BPOs were not renewable,

victim-survivors still had the option to apply for another BPO or go to court for a

Temporary or Permanent Protection Order. In Quezon City, on the other hand, barangay

officials were at a loss as to their authority to renew BPOs.

Aside from BPO issuance, it was found that barangays also extended other forms of

assistance to victim-survivors of VAWC. The most common forms of assistance are listed

below according the frequency with which they were reportedly provided, the first being

the most common:

1. Ensure the safety of the victim whether or not a BPO has been issued.

2. Ensure the enforcement of protection orders.

3. Report calls for assessment or assistance to the DSWD, the social welfare

department of LGUs, or accredited NGOs.

4. Assist barangay officials and other government officers or employees who

respond to calls for help.

5. Transport or escort the victim/s to a safe place of their choice or to a clinic or

hospital.

6. Assist the victim in removing personal belongings from the house.

7. Confiscate any deadly weapon in the possession of the perpetrator or in plain

view.

8. Arrest the suspected perpetrator even without a warrant when any act of

violence is occurring or when there is personal knowledge that an act of violence

has just been committed.

Other forms of assistance cited include informing the victim-survivor’s close

relatives about the complaint, alerting the police, extending financial assistance, counseling,

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coordinating with various local government entitites for early intervention, and educating

the perpetrator on RA 9262.

The survey reveals that only 32% of the respondent barangays has officials who are

capable of issuing BPOs. According to respondents, officials usually in charge of issuing

BPOs in their barangays are the punong barangay, barangay kagawad, and the barangay

secretary. In some barangays, the council for women, the gender and development focal

person, lupon members, and the peace and order committee are also charged with the task

of processing BPO applications. There are an average of six (6) officials in charge of issuing

BPOs in each respondent barangay.

Of the ninety-seven (97) respondent barangays, 23% was not able to provide the

needed information on BPO issuances. Some said that they failed to satisfactorily respond

because their barangay does not issue BPOs. In others, it was due to the fact that no

incidents of domestic abuse had been reported since 2004. Other reasons involve shortfalls

in record-keeping, with some barangays claiming to have no record at all of BPO issuances.

Some do not have access to records from previous barangay administrations. Still others

claim to have misplaced relevant documents. The lack of proper training on BPO issuance

was also pointed out as a reason for the failure to produce the requested data.

The validation sessions paved the way for the discussion of topics not covered by

the survey questionnaire. Participants were asked about how they learned about BPOs. In

Davao, most of the officials claim to have learned received information about them through

trainings conducted by NGOs and the Department of the Interior and Local Government

(DILG). Some took the intitiative of searching the internet for relevant laws. In Naga,

barangay officials and private citizens possessed a high level of awareness of RA 9262 and

its BPO provisions, each barangay having a women’s desk and working with volunteer

paralegals. In Quezon City however, many barangay officials reportedly lack awareness of

the relevant law and know-how to implement its provisions.

In any case, participants in all the validation sessions shared the view that barangay

officials need to be trained better on BPO issuance and VAWC in general. They opined that

most barangay officials still need to be acquainted with gender sensitivity in order to

eliminate the prevailing “macho” mindset. It was even suggested that refresher courses on

VAWC be given on a yearly basis.

Participants in the Davao validation additionally raised the difficulty encountered by

women in filing BPO applications in the same barangay where the male perpetrator

resides.

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Survey of Case Consultations Handled by SALIGAN

Starting March 2004, when RA 9262 was passed into law, SALIGAN shifted its

priority from such cases as declaration of nullity, anullment and support, to cases on

violence against women and their children. For the period of 2004-2008, a significant

amount of case consultations involved VAWC, both civil and criminal, with a number of

these having a BPO aspect.

Within this period, SALIGAN encountered a total of one hundred thiry-five (135)

cases involving violations of the Anti-VAWC law. Among the 135, twenty-eight (28) clients

reported the abuses they suffered to barangay officials and availed, or at least tried to avail,

of a BPO as a remedy. The ratio between the number of VAWC cases consulted and those

with a BPO aspect is demonstrated in Figure 1. However, in Figure 2 it will be seen that of

the 28 victim-survivors who sought relief through their barangays, only sixteen (16) were

issued BPOs, two (2) of which were denied renewal of the order upon application. Of the

twelve (12) cases where no BPOs were issued, only one (1) application was actually denied.

In the eleven (11) remaining, there is no information as per SALIGAN’s records as to

whether the applications were granted or denied. A comparison of all cases with a BPO

aspect is shown in Figure 2.

Figure 1: Total Case Consultations Involving VAWC Cases vis-a-vis

Total VAWC Consultations with a BPO Aspect

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Figure 2: Comparative Data of Case Consultations Involving

Barangay Protection Orders

Throughout the years, there has been an influx of clients seeking legal counselling

for cases involving abuse of women. However, in Figure 3 it is illustrated that from 2004-

2008, there has been a consistent decline in the number of consultations.

Figure 3: Legal Consultations Involving VAWC Cases for the Year 2004-2008

2004 2005 2006 2007 2008

Total Number

of

Consultations

Involving

VAWC

39 40 21 18 14

It is worth mentioning that as early as 2004, clients who consulted with SALIGAN

have already made use of the Barangay Protection Order as a remedy under RA 9262. A

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perusal of the records reveals that the highest number of instances where a client sought

assistance from the barangay ocurred in 2004 and 2005, with ten (10) and seven (7)

instances reported for each year, respectively. The most common kind of abuse reported

was physical abuse, with only one or two cases of verbal, psychological, emotional and

economic abuse. There is one distinct case where a BPO was availed of not by a woman

victim of violence but by a victim of child abuse.

The process that the victim-survivors followed in reporting abuses differed,

including filing a blotter with the police. There were instances where instead of issuing a

BPO, the Barangay Captain or other barangay official issued a “Certificate to File Action”

when there was failure of mediation. Some of them mediated the cases as “family affairs”

and ordered the victims and perpetrators to reconcile. There is one instance where the

barangay officials themselves battered the abuser instead of issuing a BPO.

Among those clients issued BPOs, there are two (2) whose applications for renewal

upon expiration of the orders were denied. In one of these, the barangay official concerned

informed the handling SALIGAN lawyer that as per the barangay’s legal counsel, the BPO

shoud not be renewed because the law is silent regarding its permission or prohibition.

And in a case where a BPO issued by the barangay was violated, the barangay official

advised the victim-survivor to report the incident to the police as the course of action to

take.

ISSUES and ANALYSIS

RA 9262 Unique from Other Cases

Probably the biggest obstacle in the implementation of R.A. 9262 at the barangay

level is the long-engrained role of the barangay as a mediator/conciliator of disputes in the

community. This mandate, found in RA 7160 or the Local Government Code of the

Philippines,5 provides for the establishment of the Katarungang Pambarangay or the

Barangay Justice System, a remedial structure designed to settle disputes in a simpler and

faster manner outside the courts. However, the misapplication of Katarungang

Pambarangay procedures to VAW-related cases has repeatedly hindered the effective

implementation of RA 9262 in the barangay.

As is evident from the results of the survey presented above, amicable settlement

remains a usual recourse of barangay officials for RA 9262 cases. This is also true with

5 Secs. 399 to 422.

17

respect to cases encountered by SALIGAN during consultations, in which a client was

issued a “Certificate to File Action” after failure to mediation and, in another instance,

where the punong barangay insistently advised the client to reconcile with her partner in

spite of the clear prohibition of the law against compromise.

Given these circumstances, it is obvious that barangay officials fail to appreciate the

difference between RA 9262 cases and those covered by the Katarungang Pambarangay.

An essential difference between the nature of cases in these two legal remedies lies in the

relationship of parties involved in the dispute. In the Katarungang Pambarangay system, it

is presumed that the parties are more or less of equal status or social position, where one

party cannot unduly influence the other. A concrete example of this is the relationship

between feuding neighbors. This, however, is not the case in RA 9262 disputes, as these

necessarily involve the existence of an abusive relationship between the parties. In a

relationship where there is abuse and violence, where one person is at a disadvantage and

the other possesses all the leverage, there is an obvious imbalance of power. This

imbalance is precisely what the prohibition on compromise seeks to eliminate.

The constant referral of RA 9262 cases to mediation and/or conciliation

proceedings therefore takes for granted the effects of the abusive relationship on the

complainant and defeats the very purpose of the prohibition. In instances where the

complaint alleges domestic abuse, no mediation or conciliation is necessary as the end goal

is to prevent further acts of violence from being committed, and not to achieve an amicable

settlement. Thus, in RA 9262 cases, the barangay must see itself not as a mediator or

conciliator but as a protector of the rights of abused women.

Fully Recognizing BPO as a Legal Remedy

The Barangay Protection Order is one of three kinds of protection order provided in

RA 9262.6 As differentiated from the other two which are issued by regular courts, BPOs

do not require the same formalities which are observed in court proceedings. Because it is

issued by the Punong Barangay, or a Barangay Kagawad in the former’s absence, the

requirements as well as the procedure involved in its issuance are relatively simple.

For instance, the only legal requirements for an application for a Barangay

Protection Order are that it be in writing, signed by the applicant, and in a language

understood by her/him. This simplicity of these requirements is coupled with the

simplicity of the accompanying proceedings. All RA 9262 provides is that the application

6 Permanent Protection Order, Temporary Protection Order and Barangay Protection Order.

18

shall be attested before the Punong Barangay or Barangay Kagawad, which officials shall

immediately conduct an ex parte determination of the merit of the application. The law

provides further that the BPO must be issued immediately upon the conclusion of said ex

parte proceeding.7 The law has made applying for a BPO so straightforward specifically to

provide victim-survivors easy and immediate access to this remedy, and to ensure that they

are given adequate legal protection from further violence or abuses. The creation of a legal

remedy that barangays can provide seeks to maximize its status as the LGU “closest” to the

victim-survivor.

Still, many fail to appreciate the nature of a BPO as a legal remedy. Whether from

lack of knowledge or outright disregard of the law, many applications end up being denied

or dismissed due to causes such as amicable settlement or reconciliation. RA 9262 provides

clear, specific rules on the issuance of a BPO, giving no room for any form of mediation or

reconciliation. The continued divergent practice of barangay officials undermines the

nature of the BPO and deprives victim-survivors of their full right to this legal remedy.

In some cases it is the victim-survivor herself who causes the dismissal of her

application, due to fear, lack of financial security, and consideration of her children’s well-

being. Such concerns are valid and in fact taken into account under the law. Behind the

“voluntary” dismissal of BPO applications, there is actually a lack of awareness on the part

of the victim-survivor regarding her rights, and on the part of the Barangay of their

responsibilities under the law. It is therefore essential for barangay officials to be able to

present BPOs to victim-survivors as readily accessible and effective so that it can serve its

purpose as a legal remedy.

Understanding the Forms of Abuse Covered by RA 9262

The result of the barangay survey shows that physical abuse is the most common

form of violence identified by victims who have approached the barangay for assistance.

Phyical abuse as a ground for BPO application surpassed all other forms of abuse covered

by RA 9262 – psychological, sexual, and economic – by a considerable margin, the incidence

of all three combined totalling less than the incidence of physical abuse alone.

This prevalence of physical abuse as a ground for BPO applications may mean two

things: that it is indeed the most common form of violence inflicted on women by

perpetrators, and/or that most applicants remain unaware that non-physical forms of

abuse are also covered by the Anti-VAWC law. In the Davao validation, for instance, the

7 Sec. 14, RA 9262 Implementing Rules and Regulations (IRR).

19

participants explained that forms of abuse other than physical, particularly financial abuse,

only come out while the applicants are narrating their stories. In SALIGAN’s case

consultations, likewise, it is seldom that a client will readily identify sexual, psychological

and financial abuse as part of their experience, even though instances of such will apear in

their narration of facts.

While it is truly alarming that so many women still experience physical abuse in

their intimate relationships, despite the presence of the Anti-VAWC law and other

measures in place for its prevention, it is an equally distressing fact that until now, the

various forms and acts of violence prohibited and punished under the law remain

unrecognized or misunderstood. Both reasons point to the continuous failure in

enforcement by barangay officials and the police, as well as the lack in education and

information dissemination regarding the provisions of RA 9262 for relevant actors.

Low Number of BPOs Applied for and Issued

In the survey question ascertaining the number of BPOs filed with, issued, dismissed

and amicably settled by a barangay, there was a considerably low turnout of BPOs filed or

applied for and issued – an average of 9.58 and 8.63, respectively, over a period of more

than 3 years. Four possible reasons may explain this.

First, it may be that there are fewer cases filed because there is a lower incidence of

violence in the domestic sphere, perpetrators being more aware of the law and refraining

from committing further acts of abuse against their partners and their children. This

proposal is of course extremely optimistic. Second, it is possible that few cases are brought

by victims to the barangay for the same reasons that they fail to pursue cases already filed

against their abusers: fear, lack of financial capacity, lack of knowledge about their rights

and the law, consideration of their children’s well-being, among others. Third, it may again

be due to the fact that barangay officials resort to settlement and reconciliation of cases

involving VAWC, that is why BPO applications either do not reach the point of being “filed”,

or none are issued because they have already been resolved.

Lastly, and quite unfortunately, it may also point to a degree of confusion

experienced by the barangays that responded to the survey. For one, most barangays

surveyed indicated fewer cases filed with them than BPOs they issued, dismissed or settled

altogether, whereas the goal of the particular survey question was to gain an overview of

the trend of responses to BPO applications. There is an apparent lack of familiarity with

technical terms used in the law. For example, in the Davao validation, participants said that

understanding of the word “file” means to bring the case to court, while “issue” is to grant

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or give the BPO. They explained that when a victim goes to the barangay to ask for a BPO,

they usually refer to it as an “application” rather “filing”.

Proper Assistance to Victim-Survivors in Filing Court Cases

Other than issuing BPOs, barangay officials are required to provide assistance to a

victim-survivor in filing the necessary application for protection in court. Sec. 14 (d) of the

IRR of RA 9262 provides as follows:

The BPO shall be issued free of charge. Within twenty four (24) hours after a

BPO is issued, the Punong Barangay, or in her/his absence or inability, any

available Barangay Kagawad shall assist the victim-survivor/petitioner in

filing for an application for a TPO or PPO with the nearest court in the place

of residence of the victim-survivor…. For indigent petitioner, the barangay

shall ensure that transportation and other expenses are provided for in filing

for an application for a protection order with the courts.

As the barangay protection order is limited in scope, this mandate is important to

ensure that a further remedy due the victim-survivor is pursued, be it civil or criminal.

Under this provision, it is the obligation of barangay officials not only to inform the victim-

survivors of their right to pursue a case in court, but also to facilitate access to it. In fact,

the provision additionally mandates the barangay to provide financial assistance to those

unable to pay for transportation and other expenses related to the filing of an application

with the court.

However, based on the data gathered in the survey, only 33% of barangay

respondents said that they have been able to assist the victim-survivors in filing

appropriate cases in court. A similar result will be revealed if SALIGAN consultations are

examined, as there is very little showing of instances where barangays were able to go

beyond the issuance of BPOs to assist in filing relevant court cases.

It is important to note that while the barangay protection order by itself serves as a

sufficient ban against further violent or abuses, it cannot offer any other reliefs outside

those provided in the law. Section 13 of the IRR of RA 9262 limits the reliefs that may be

granted through a BPO to the following:

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a. Prohibition of the respondent from threatening to commit or committing,

personally or through another, any of the following acts mentioned in Section 7

(a) and (b) of these Rules;8 and

b. Prohibition of the respondent from harassing, annoying, telephoning, contacting

or otherwise communicating with the victim-survivor, directly or indirectly.

The filing of the necessary action in court therefore is essential to ensure that a

victim-survivor of violence may avail of the full gamut of protective issuances available to

her legally, either by petitioning for a Temporary or Permanent Protection Order, or by

pursuing a criminal action. The failure of barangay officials to provide assistance in filing

these kinds of cases may be deemed a serious disregard of their obligations under RA 9262,

which puts the victim-survivor at risk because it fails make all possible remedies readily

available and accessible to her.

Compliance with the Mandated Period for Issuance of a BPO

The rule on the length of time for the issuance of a barangay protection order is

clear under RA 9262. Section 14 of the law provides that a Punong Barangay who receives

an application for BPO shall issue the order on the date of filing after ex parte determination

of the basis of the application. The implementing rules add that the ex parte determination

of the application’s merit shall have priority over all proceedings before the barangay,9 and

that the BPO must be issued on the same day of application, immediately upon the

conclusion of the ex parte proceedings.10 And, if we are to construe the rule strictly, the law

in fact exacts a more stringent period as it states that BPO must be issued on the same day

of the application upon conclusion of the ex parte proceedings.

While the rule may be clear on paper, much is left to be desired in its

implementation. Based on the survey, the issuance of Barangay Protection Orders takes

place within an average of five (5) days from when they were applied for. Despite these

respondent barangays being familiar with the rule regarding period of issuance, only a

handful actually issue BPOs within 24 hours or on the same day of the application.

We go back to the nature of barangay protection order for the reason behind the 24-

hour rule. As the most immediate form of relief available to women-survivors, the law not

only simplified the requirements and procedure for the issuance of BPOs, but also ensured

8 These are causing (a) physical harm to the woman or her child and (b) threatening to cause the woman or her child physical harm. 9 Sec. 14 (a), RA 9262 IRR. 10 Sec. 15 (b), Id.

22

that they will be granted swiftly and immediately. Regardless of the reason for the delays in

BPO issuance, the intent of the rule is defeated when the period is extended beyond what is

provided in the law. This is why observance of the mandated period should be strictly

observed. Any delay in the issuance of a BPO leaves the victim-survivor without any legal

protection from abuse that much longer, and is considered a denial of her right under the

law.

Renewal of a BPO After the Lapse of its Effectivity

A usual issue encountered by SALIGAN during legal consultations is the refusal of

barangays to renew issued BPOs. In the twenty-eight (28) consultations that involved

applications for or the issuance of a BPO, five (5) involved its renewal. Out of these, the

barangay in three (3) cases granted the application for renewal, while (2) declined to do so

on the ground that it is contrary to what the law provides. 35% of the survey respondents

said that they allow renewal and/or extension of BPOs while 65% do not.

The reason for this conflict in application is the absence of a provision in RA 9262 on

the automatic renewal of BPOs, unlike that provided for Temporary Protection Orders.

Section 16 of the law provides for the continuous extension or renewal of TPOs for 30 days,

until final judgment on the petition for the issuance of a permanent protection order is

issued. Unfortunately, no similar provision exists for BPOs. The absence of an express

provision allowing their extension or renewal has led barangay officals to believe that

these are prohibited. In fact, some participants in the Davao validation workshop even said

that they have attended orientations on BPO where they were given information to this

effect.

SALIGAN is of the opinion, however, that the absence of an express provision

allowing the extension or renewal of BPOs does not automatically prohibit the same, absent

a categorical statement to the contrary. Because while the law does not directly allow

renewal, neither does it expressly prohibit it. Moreover, if we apply Section 4 of RA 9262 –

directing a liberal construction of the law to promote the protection and safety of victims of

violence against women and children – the more prudent interpretation would be that a

BPO may be renewed or extended so long as the ground for its issuance still exists, or until

a TPO is issued in its stead. This interpretation will ensure that victim-survivors are given

protection throughout the entire legal process, and is in keeping with the aim of the law to

most effectively prevent further harm from coming to women and their children.

CONCLUSION AND RECOMMENDATIONS

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Very apparent from the foregoing legal framework, data and analysis is the yawning

gap between the intention of the law on the Barangay Protection Order and its

implementation. Five years from the enactment of RA 9262 and the availability of a simple

and accessible remedy through the barangay, it is alarming to see that the BPO mechanism

has not been fully utilized and has even been the source of further abuse against women.

Instead of serving as a basis for their protection, this crucial means of empowering victims

of domestic violence has been used to compel them to reconcile with their abusers, and

they have repeatedly been refused the assistance that is their right under the law.

Through the validation workshops conducted in Davao, Naga and Quezon City, as

well as SALIGAN’s own experiences, a number of recommendations have been gathered to

address the issues presented above. In both the workshops and the survey, lack of

information was identified as the primary obstacle to the effective implementation of BPOs.

Most, if not all, of the issues identified may be attributed to the near-absence of a deliberate

process of information-dissemination about the law, whether geared towards

implementers, women, perpetrators, or other stakeholders. It is widely viewed that an

effective awareness program, particularly at the barangay level, will address the multiple

issues of conciliation in RA 9262 cases, failure to maximize BPO as a legal remedy, non-

compliance with many of the requirements of the law, and non-recognition of the different

benefits it provides.

Turn the focus on the purpose and intent of the law

The proper implementation of a law that is as unique and groundbreaking as RA

9262 could only come from a complete understanding of its basis and purpose. It is quite

unreasonable to expect barangays to withdraw from their long-established role of

mediator, particularly in the Katarungang Pambarangay system, after a mere reading of the

law. Thus there needs to be a re-orientation, or an orientation where none has been carried

out, as to the prohibition on conciliating and mediating cases covered by RA 9262 in the

context of the spirit of the law. By enabling barangays to understand the crucial distinction

between ordinary conflicts and cases of VAW, it is hoped that the habit of initiating or

compelling the conciliation between parties will be curbed or altogether stopped. This will

entail the formation of gender sensitive barangay officials and workers who have a keen

grasp of the nature of gender inequality and discrimination, and the function of RA 9262 as

a strategic response to these problems. Other than this, there is also a need to convert

anecdotal accounts of barangays’ various misapplications of the law into actual court or

administrative cases. Litigators should pursue precedent-setting cases, specifically those

that would lead to a Supreme Court decision that rules against barangay officials’ unlawful

reconciliation initiatives.

24

At the same time, a correct understanding of RA 9262 as a piece of social legislation

may also remedy the issue of non-renewal of BPOs due to conflicting interpretations of the

law. Indeed, its only interpretation should be in favor of the women and children it seeks to

protect. If implementers are encouraged to look beyond the letter of the law, and take its

silence on the matter of BPO renewal with the true purpose of the remedy in mind, there

will exist no confusion as to whether or not BPOs can be renewed. Of course, another

recourse would be to amend the law or for the DILG to come out with an Opinion on its

correct application. In the meantime, however, information campaigns regarding BPO must

include renewal as a crucial aspect of its full implementation.

Increase the level of trust in the BPO mechanism

While it is very difficult to single out the main reason for the low number of BPOs

issued since the implementation of RA 9262, it is clear that there is an urgent need to

increase the public’s level of trust in the BPO mechanism. One very real proof of this is the

great number of VAWC victim-survivors that continually seek the aid of SALIGAN and its

partner organizations such as the Women’s Crisis Center (WCC). Equipping implementers

and victims with ample knowledge of the law will necessarily result in confidence in its

utilization and the frequency of its proper application. Through this, the reasons for

hesitation or desistance in the application for and issuance of BPOs will be reduced to

substantive matters, and no longer include superficial grounds such as lack of interest, lack

of knowledge of the law and lack of confidence, lack of privacy in the barangay, the desire

to maintain barangay neutrality, and the like.

Institutionalize a systematic training program for barangay officials

The need for widespread and systematic training of barangay officials on the

Barangay Protection Order is the primary activity that must be undertaken in this entire

endeavor. At this late point in the law’s enactment, too many barangays remain ill-

equipped with technical and practical know-how on its interpretation and application

despite being the first-liners in its implementation. The issue of political will does not even

come into the picture, as the more basic matter of legal and skills literacy about BPOs has

yet to be recognized and addressed.

Foremost is the need for the government to allocate resources for a training

program that will cover all barangays throughout the country, comprehensively carried out

and not merely in a random or limited manner. A two-day training on gender sensitivity

25

and the contents of RA 9262 would go a long way in addressing implementation problems.

These trainings should take place immediately after new barangay officials are elected or

appointed, and should be repeated for new batches of officials until the knowledge is

sufficiently ingrained in the barangay system. The contents of the training should also be

contained in a simple and comprehensive manual for easy reference.

NGOs like SALIGAN have begun engaging with barangays for BPO trainings, but it is

government that has the means and mechanisms to take on a comprehensive education

campaign among all barangay leaders. The effort of various NGOs and people’s

organizations (POs) to make barangays more responsive to the needs of women victim-

survivors is one aspect, but a bigger push must come from government itself in order for

barangay officials to become truly effective and capable implementers. In this connection,

SALIGAN is of the strong belief that the DILG must at this time come out with an

administrative issuance that will not only require barangay officials to undergo training on

the BPO, but also provide sanctions for their failure to fulfill their duties in enforcing this

remedy.

Conduct a massive awarness program for the general public

In conjunction with this effort, the DILG and interested NGOs and POs should also

undertake a massive awareness program for the general public about the existence of the

BPO – as an immediate remedy in incidents of physical violence against women and their

children, and the simple process by which it can be availed. Print, radio and television

media appear to be the most efficient means of information dissemination. Advertisements

could be produced and guestings on radio and television shows could be explored in order

to inform the public about the availability of the protection order. One progressive

alternative is the establishment of an internet-based portal dedicated specially to BPO

information, where anyone interested may simply download forms, receive updates, and

get in touch with agencies, groups and individuals who may extend victims assistance.

At the local level, this could be complemented with efforts such as poster drives in

common places within the barangay, educational sessions in pulongs or meetings, and

distribution of flyers and other reading materials in vernacular languages that dwell on the

technical and procedural aspects of the BPO. Women's month activities may be maximized

as opportunities for fostering education and building awareness in the barangay. Other

than these, implementers and other stakeholders may come up with innumerable creative

ways to ingrain the Barangay Protection Order in the public consciousness, at the same

time helping to do away with the stigma attached to voicing out and confronting incidents

of violence against women.

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Other recommendations

Assistance in filing court cases is among the duties imposed on barangays under RA

9262. Such assistance is supposed to sufficiently supplement the limited reliefs available

through a BPO. However, as observed through the present study, this duty has been largely

neglected – few barangays have taken on the task of going beyond mere issuance and into

assistance with filing of cases.

The first major hurdle in implementing this neglected provision of RA 9262 is the

lack of resources. Funds should be allocated for the VAWC litigation expenses of barangays.

This should not be very difficult as it has been raised in various fora that LGUs are at a loss

on how to utilize their gender and development (GAD) budgets. Barangays should be

provided with clear recommendations and guidelines on how they could access their GAD

funds for this purpose, along with the delivery of other services required under RA 9262

such as serving and enforcing protection orders, transporting victims of VAW to a hospital

or other safe place, assisting her in getting her belongings, etc. This recommendation

should be considered along with the earlier proposal for a nationwide barangay training

program on gender sensitivity and RA 9262.

Aside from a continuous and comprehensive education and training program that

would clarify the requirements of law among barangay officials, the immediate issuance of

BPOs would be greatly facilitated by the availability of pro-forma applications and orders

which applicants and barangay officials would only have to fill out and sign. The DILG has

circulated copies of these forms, but there is still a considerable number of barangays that

are completely unfamiliar with what these forms should contain and how they should be

prepared.

An institutionalized mechanism for coordination between barangays where the

victim-survivor resides and where she is located, if she has temporarily moved to protect

herelf from further abuse, as well as between the barangay where she is located and where

the perpetrator is located, should they be different, will go a long way in ensuring that the

BPO mechanism will not be circumvented by the limited jurisdiction of barangays who

have issued BPOs. Along with this, there should also be improved coordination and

partnership between the barangay and the local police so that police assistance will be

readily available in case of difficulties in enforcing a BPO. Such efforts at coordination will

greatly enhance the scope, reliability and effectiveness of the Barangay Protection Order.

27

Geared towards a more efficient and effective system of applying for and providing

BPOs, SALIGAN hopes that these recommendations will help enable barangays to fulfill

their primary role in protecting victims of violence, and contribute to giving Filipino

women a better and stronger chance of ending the abuses inflicted upon them by obtaining

a genuine grasp of their right to a Barangay Protection Order.

We in SALIGAN believe that advocacy work does not end with getting a law passed –

ensuring its implementation is an integral part of any advocacy. Thus the same zeal and

persistence that marked the success of lobbying efforts for RA 9262 should also be

manifest in seeing that those accountable under the law perform their functions faithfully.

And because the barangay is the venue closest and most accessible to women-victims and

survivors, it is the bounden duty of both public and private sectors to make sure that our

barangays take full responsibility of their legal mandate to protect victims, curb further

incidences of domestic violence, and be a dominant force in eliminating all forms of

violence against women.#