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 39 40 21 18 14
Involving
VAWC

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.

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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.

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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).

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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.

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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.

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 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

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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.

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 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.#

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