Araza's marital infidelity caused AAA severe emotional distress, leading to his conviction under R.A. No. 9262 for psychological violence. The Supreme Court upheld the ruling, affirming damages and penalties.
In the case of Jaime Araza y Jarupay vs. The People of the Philippines (G.R. No. 247429), the petitioner, Jaime Araza, was accused of violating the Anti-Violence Against Women and Their Children Act of 2004, specifically under Section 5(i) which pertains to psychological violence. The events leading up to the case took place primarily from 2007 to 2014, during which time Araza's wife, identified only as AAA, experienced emotional and mental distress resulting from Araza’s extramarital affair with Tessie Luy Fabillar. The marriage between Araza and AAA was solemnized on October 5, 1989.
AAA testified that tensions in their marriage began after Araza’s trip to Zamboanga City for a business opportunity in early 2007. Following this trip, AAA received various anonymous messages informing her of Araza's infidelity, which led her to Zamboanga where she confirmed the affair. Upon discovering that Araza was living with Fabillar and had fathered three children with her, AAA filed
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Case Digest (G.R. No. 247429)
Facts:
Procedural Background and Charge
Jaime Araza y Jarupay (petitioner) was charged under Section 5(i) of Republic Act (R.A.) No. 9262, known as the Anti-Violence Against Women and Their Children Act of 2004, for committing acts of psychological violence against his wife, AAA.
The complaint alleged that Araza, with intent to humiliate and degrade his wife, engaged in marital infidelity by maintaining a live-in relationship with his mistress, Tessie Luy Fabillar, and fathering three illegitimate children with her.
The Information stated that Araza’s actions caused emotional anguish and mental suffering to his wife.
Chronology of Events and Circumstances
Marriage and Early Years
- Araza and AAA were married in 1989 and initially led a harmonious life.
- In February 2007, while Araza went to Zamboanga City for their networking business, AAA noticed changes in his behavior, including appearing depressed and anxious.
- On September 3, 2007, AAA personally confirmed that Araza was living with another woman, Tessie Luy Fabillar, which later led her to file a complaint against him and his alleged mistress.
- The complaint for concubinage was amicably settled after an agreement was executed between Araza and Fabillar to refrain from further contact.
- However, Araza soon abandoned AAA on November 22, 2007, only to resume living with his mistress, thus renewing the cycle of emotional distress for AAA.
- Over the years, AAA undertook various measures including seeking police and NBI interventions, filing multiple cases, and even undergoing hospitalization due to severe emotional and psychological turmoil.
Evidence Introduced by the Parties
Prosecution Evidence
- Witness testimonies from AAA, a private complainant who detailed her firsthand experience of betrayal and subsequent emotional suffering.
- Armando Que, a friend and associate of the parties, testified to witnessing Araza and Fabillar together during their business activities.
- Dr. Kristina Ruth B. Lindain, as an expert witness, provided an assessment of AAA’s psychological condition, indicating that her symptoms were consistent with the distress caused by the relational turmoil.
- Araza testified in his defense, admitting to leaving his wife and living with Fabillar but denying any intentional act to cause her harm.
- He dismissed the allegations by attributing the marital discord to personal grievances involving financial disputes and emotional discord, while denying paternity of the children with his mistress.
Trial Court and Appellate Proceedings
Regional Trial Court (RTC) Findings
- The RTC, in its October 30, 2017 decision, determined that Araza’s actions constituted psychological violence as defined under R.A. 9262.
- It found that the act of marital infidelity, combined with his abandonment of AAA, caused demonstrable emotional and mental suffering, as affirmed by the testimonies of AAA and Dr. Lindain.
- Araza was convicted, and the RTC imposed an indeterminate penalty ranging from six (6) months and one (1) day of prision correccional as a minimum to eight (8) years and one (1) day of prision mayor as a maximum, along with a fine and moral damages.
- The CA affirmed the RTC’s findings, holding that the prosecution had sufficiently established all the elements of the crime.
- It denied Araza’s appeal and motion for reconsideration, reiterating that the Information adequately charged the offense.
- Araza’s petition for review on certiorari was ultimately denied for lack of merit, with the CA decision being affirmed with modifications that included the imposition of mandatory psychological counseling.
Issue:
Sufficiency of the Information
Whether the CA erred in affirming Araza’s conviction despite the contention that his conviction was based on acts not specifically alleged in the Information.
Adequacy of Evidence and Burden of Proof
Whether the prosecution failed to prove beyond reasonable doubt the occurrence of the acts committed by Araza that led to AAA’s mental and emotional suffering.
Causation of Emotional and Psychological Distress
Whether the prosecution established that Araza’s act of marital infidelity was the proximate cause of AAA’s emotional anguish and mental suffering.