Case Digest (G.R. No. 229762)
Facts:
In AAA vs. People of the Philippines, the petitioner AAA was charged by information dated February 17, 2010 in Iligan City with violating Section 5(i) of Republic Act No. 9262 or the Anti-Violence Against Women and Their Children Act of 2004 for willfully removing conjugal properties from the home of his wife, BBB, and carrying them to his mother’s house against her will, thereby causing her mental and emotional anguish. At the Regional Trial Court (RTC) of Iligan City, Branch 2 (Criminal Case No. II-14837), petitioner pleaded not guilty; BBB and her daughter CCC testified to heated arguments, verbal abuse, physical “mauling,” and removal of appliances and furniture. AAA testified that he acted in good faith to protect items used as loan collateral and only pushed his wife aside. The RTC found all elements of Section 5(i) satisfied and sentenced him to an indeterminate penalty of six months and one day of prision correccional to eight years and one day of prision mayor. On appeaCase Digest (G.R. No. 229762)
Facts:
- Antecedents
- On February 17, 2010, AAA (petitioner) and his wife BBB (private complainant) had a heated argument over debts allegedly incurred by BBB, which used their television set and refrigerator as collateral.
- Petitioner removed several conjugal properties (TV, refrigerator, divider, “sleeprite” bed, dining table) to his mother’s house; BBB attempted to stop him and testified that he “mauled” her, causing mental and emotional anguish.
- Proceedings Below
- Regional Trial Court (RTC) of Iligan City, Branch 2, Criminal Case No. II-14837
- Information charging petitioner with violation of Section 5(i), R.A. No. 9262 (Anti-Violence Against Women and Their Children Act of 2004).
- Petitioner pleaded not guilty; trial on merits.
- RTC Decision (January 22, 2013)
- Found all elements of Sec. 5(i) satisfied: marriage, acts constituting violence (removal of conjugal properties, physical “mauling,” verbal abuse), and resultant mental/emotional anguish.
- Sentence: Indeterminate penalty — six months & one day prision correccional to eight years & one day prision mayor.
- Court of Appeals (CA) in CA-G.R. CR No. 01170-MIN
- Affirmed RTC’s factual findings and conviction; proved mental/emotional anguish by victim’s testimony.
- Applied mitigating circumstance of passion and obfuscation; reduced maximum penalty to six years & one day prision mayor.
- Denied petitioner’s motion for reconsideration (Resolution, January 12, 2017).
- Supreme Court Petition
- AAA filed a petition for review on certiorari under Rule 45 seeking reversal of CA’s October 28, 2019 Decision and January 12, 2017 Resolution.
- Issues raised:
- Violation of presumption of innocence (insufficiency of evidence).
- Whether petitioner’s act constituted emotional/psychological abuse.
Issues:
- Whether the prosecution overcame the constitutional presumption of innocence of the petitioner.
- Whether the act of removing conjugal properties without intent to humiliate constitutes mental or emotional abuse under Section 5(i) of R.A. No. 9262.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)