SHARICA and Steve were married for six years, and the wife petitioned for the issuance of a Temporary Protection Order against her husband, and included the man’s parents, for causing her verbal, psychological and economic abuse. Pitiful woman. The entire family ganged up on her. The parents of Steve, or Sharica’s parents-in-law, filed a motion to dismiss arguing that they are not covered under the Violence Against Women law as they don’t have a direct married relationship to Sharica. The RTC dismissed the petition as against the parents-in-law saying that RA 9262 is specific and does not include persons other than those with marriage, former marriage or has or had a dating or sexual relationship with the woman-victim. On appeal to the Supreme Court, it was ruled that RA 9262 defines “violence as any act or a series of acts committed by a person against a woman who is his wife, former wife, or against a woman with whom the person has or had a sexual or dating relationship, or with whom he has a common child, whether legitimate or illegitimate, within or without the family abode, which result in or is likely to result in physical, sexual, psychological harm or suffering, or economic abuse including threats, or economic abuse including threats or such acts, battery, assault, coercion, harassment or arbitrary deprivation of liberty.” Moreover, Sec. 47 of RA 9242 provides that the Revised Penal Code shall have suppletory application to the this Act. Relative thereto, Art. 10 of the Revised Penal Code provides that “Offenses which are or in the future may be punishable under special laws are not subject of this Code. This Code shall be suppletory to such laws, unless the later should specially provide to the contrary.” From these provisions, it is apparent that the Revised Penal code finds suppletory application. Thus the Supreme Court ruled that while RA 9262 “provides that the offender be related or connected to the victim by marriage, former marriage, or a sexual or dating relationship, it does not preclude the application of the principle of conspiracy under the RPC”. Hence, very clearly, the parents-in-law or any other person not related by marriage or former marriage to the victim, or not having or had a sexual or dating relationship with the victim, can still be included as respondents in cases of violations of RZ 9262 by reason of Conspiracy. This ruling in the case of Sharica Mari Go-Tan vs. Perfecto and Juanita Tan (G.R. No. 168852, September 30, 2008) finds importance in the many cases where the in-laws are the primary perpetrators of the violence against the daughter-in-law and the mama’s boy husband only becomes a hapless aggressor, conspirator or violent man with the support of his parents. E-mail: joepallugna@yahoo.com