Case Digest (G.R. No. 169726) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In AAA v. BBB (G.R. No. 212448, January 11, 2018), petitioner AAA and respondent BBB were married on August 1, 2006, in Quezon City and bore two children, CCC (b. March 4, 2007) and DDD (b. October 1, 2009). In May 2007, BBB began working in Singapore as a chef and became a permanent resident in September 2008, while AAA and their children resided first in Quezon City and then, from March 2010, at AAA’s parents’ home in Pasig City. In April 2011, AAA alleged that BBB had an illicit relationship with a Singaporean woman, Lisel Mok, causing her mental and emotional anguish as confirmed by photographs and an e-mailed letter from BBB’s mother. On April 19, 2011, the local prosecutor found probable cause to charge BBB under Section 5(i) of R.A. No. 9262 for psychological violence committed through marital infidelity, and the Information was filed with RTC Pasig City, Branch 158. A warrant of arrest and a hold-departure order followed, but BBB evaded service. In November 2013, BBB’s c Case Digest (G.R. No. 169726) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Marriage
- AAA (petitioner) and BBB (respondent) were married on August 1, 2006 in Quezon City; they have two children: CCC (b. March 4, 2007) and DDD (b. October 1, 2009).
- In May 2007, BBB went to Singapore to work as a chef, obtaining permanent residency in September 2008. AAA and the children lived with AAA’s parents in Pasig City from March 2010 onward.
- Allegations and Procedural History
- AAA alleged that BBB provided little financial support, committed physical and sexual violence, mistreated the children, and maintained an illicit relationship with a Singaporean woman, Lisel Mok, causing AAA mental and emotional anguish. A violent altercation occurred in a Singapore hotel on April 19, 2011.
- Prosecutor found probable cause to charge BBB under Section 5(i) of R.A. No. 9262 for causing mental or emotional anguish through marital infidelity; a warrant of arrest and hold‐departure order (HDO) were issued. BBB evaded both, and the case was archived.
- On November 6, 2013, BBB’s counsel filed a motion to revive the case, quash the information, and lift the HDO and warrant. On February 24 and May 2, 2014, the Regional Trial Court (RTC) of Pasig City, Branch 158, granted the motion to quash for lack of territorial jurisdiction, reasoning that the criminal act (infidelity) occurred in Singapore.
- Petition to the Supreme Court
- AAA filed a petition for a writ of certiorari under Rule 45, arguing that mental and emotional anguish, being experienced wherever she resides, is an essential element and that under Section 7 of R.A. No. 9262 venue lies where any element of the crime occurred.
- BBB contended the quash amounted to an acquittal (appealable only by the OSG), that AAA lacked standing, and that the petition was late. The Supreme Court found the petition timely and raised solely a question of law.
Issues:
- Whether Philippine courts have territorial jurisdiction under R.A. No. 9262 to try an offense of psychological violence (Section 5(i)) committed through marital infidelity when the illicit relationship and the acts complained of occurred outside the Philippines.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)