Case Digest (G.R. No. 247429) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Araza y Jarupay v. People (G.R. No. 247429, September 8, 2020), petitioner Jaime Araza y Jarupay (Araza) was charged by Information filed in September 2007 before the Regional Trial Court (RTC) of Las Piñas City, Branch 199, with violation of Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004). The Information alleged that Araza, with intent to humiliate and degrade his lawful wife AAA, willfully committed psychological abuse by engaging in marital infidelity with Tessie Luy Fabillar, begetting three illegitimate children and causing AAA emotional anguish and mental suffering. At the RTC, the prosecution presented AAA, a friend Armando Que, and Dr. Kristina Ruth Lindain (psychiatrist) to establish infidelity, psychological violence, and resultant mental distress. Araza testified in denial but admitted living with Fabillar. The RTC found him guilty on October 30, 2017, sentencing him to an indeterminate term of six months and one Case Digest (G.R. No. 247429) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charge
- Petitioner: Jaime Araza y Jarupay (Araza), lawful husband of AAA.
- Respondent: People of the Philippines.
- Charge: Violation of Section 5(i) of R.A. No. 9262 (psychological violence) for committing marital infidelity with Tessie Luy Fabillar and fathering three illegitimate children, thereby causing emotional anguish and mental suffering to AAA.
- Factual Background
- Marriage and Early Years
- AAA and Araza married on October 5, 1989; initially living harmoniously.
- Araza ceased OFW work in 1993 to join AAA’s networking business.
- Alleged Infidelity and First Complaint
- In February 2007, Araza went to Zamboanga for business; AAA noticed mood changes.
- AAA received texts alleging Araza’s affair; on September 3, 2007, she confirmed he cohabited with Fabillar.
- AAA filed concubinage complaint against Araza and Fabillar at the PNP; case settled by signed agreement to separate.
- Desertion, Investigations, and Health Impact
- November 22, 2007: Araza left AAA without explanation; AAA sought NBI help and filed a habeas corpus petition (dismissed).
- AAA received threatening texts and believed Araza was detained by Fabillar.
- AAA suffered insomnia, asthma attacks, depression; underwent hospitalization and took antidepressants and sleeping pills.
- Trial Proceedings at the RTC
- Prosecution witnesses:
- AAA – recounted affair, desertion, emotional suffering.
- Armando Que – observed Araza and Fabillar together.
- Dr. Kristina Lindain – expert opinion on AAA’s distress (depressed mood, sleeping difficulty).
- Defense witness: Araza – denied infidelity but admitted desertion and cohabitation with Fabillar.
- October 30, 2017 RTC Decision: Found Araza guilty beyond reasonable doubt.
- December 17, 2018 CA Decision and May 10, 2019 Resolution: Affirmed RTC decision.
Issues:
- Whether the CA erred in affirming conviction based on facts not alleged in the Information (abandonment, detention pretense).
- Whether the CA erred in ruling that the prosecution proved Araza’s acts beyond reasonable doubt.
- Whether the CA erred in finding that AAA suffered mental and emotional anguish proximately caused by Araza.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)