Case Digest (G.R. No. 243049)
Case Digest (G.R. No. 243049)
Facts:
XXX v. People of the Philippines, G.R. No. 243049, October 05, 2020, Supreme Court Second Division, Delos Santos, J., writing for the Court. This Rule 45 petition seeks review of the Court of Appeals’ Decision dated January 24, 2018 and Resolution dated October 29, 2018 in CA‑G.R. CR No. 39608, which affirmed the Regional Trial Court’s conviction of XXX for violation of Section 5(i) in relation to Section 6(f) of Republic Act No. 9262 (Anti‑Violence Against Women and Their Children Act of 2004).The private complainant, identified in the record as AAA, testified that she and petitioner were married for 17 years and had two children. Their marriage deteriorated after allegations of petitioner’s extramarital affair and that he had sired a child with another woman, Rona Matchimura. AAA recounted that after confronting petitioner she was met with denial, they argued violently, and she thereafter left the conjugal home; she alleged emotional and psychological injury to herself and to their eldest child, who suffered a nervous breakdown. AAA received a threatening text message from petitioner on June 6, 2013 and subsequently filed a criminal complaint and sought a protection order, which the Metropolitan Trial Court in Cities granted and later made permanent.
Petitioner testified in his own defense, denied the affair allegations generally but admitted on cross‑examination to past acts of infidelity, and said he left the marital home and later that AAA executed an affidavit of desistance for the sake of their daughter. The RTC (Branch 39) in a Decision dated February 24, 2016, penned by Judge Manuel C. Luna, Jr., found petitioner guilty beyond reasonable doubt of psychological violence under Sec. 5(i) in relation to Sec. 6(f) of RA 9262, imposed an indeterminate term of imprisonment and a P100,000 fine, and the petitioner appealed to the Court of Appeals.
The Court of Appeals, in a Decision dated January 24, 2018 (authored by Associate Justice Magdangal M. De Leon, with concurrences), dismissed the appeal, giving great weight to the RTC’s credibility findings, and sustained that petitioner’s admission on cross‑examination constituted a judicial admission establishing infidelity. A Motion for Reconsideration to the CA was denied in a Resolution dated October 29, 2018. Petitioner sought and obtained a brief extension to file a petition for review under Rule 45, and timely filed this petition in the Supreme Court. The Court resolved the petition by affirming with modification.
Issues:
- Did the prosecution prove beyond reasonable doubt the elements of psychological violence under Section 5(i) in relation to Section 6(f) of RA 9262 so as to sustain petitioner’s conviction?
- Was the constitutional presumption of innocence properly overcome by the evidence introduced against petitioner?
- Did the trial court and the Court of Appeals err in failing to order mandatory psychological counseling or psychiatric treatment as part of the penalty under Section 6 of RA 9262?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)