Case Digest (G.R. No. 144413)
Facts:
In XXX v. People of the Philippines (G.R. No. 250219, March 1, 2023), petitioner XXX was charged on January 29, 2016, with violation of Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004) before the Regional Trial Court (RTC) of Valenzuela City, Criminal Case No. 194-V-16. The Information alleged that from October 2015 up to the present, petitioner, being the husband of the victim AAA, willfully and unlawfully deprived AAA and their minor daughter, BBB, of financial support legally due them and totally abandoned them, thereby causing psychological and emotional anguish. AAA had gone to work in Singapore but returned upon discovering petitioner’s romantic relationship and cohabitation with another woman, CCC, who became pregnant by him. Text messages exchanged between petitioner, CCC, and AAA demonstrated repeated verbal abuse, humiliation, and an admission of infidelity. BBB, then nine years old, tearfully testified about her emotioCase Digest (G.R. No. 144413)
Facts:
- Charge and Procedural History
- On January 29, 2016, an Information was filed charging petitioner XXX under Section 5(i) of Republic Act No. 9262 (RA 9262) for “willfully, unlawfully, feloniously” depriving his wife (AAA) and their minor child (BBB) of financial support and abandoning them, causing psychological and emotional anguish.
- Petitioner moved to quash the Information and arrest warrant for lack of due process; the RTC granted the motion (March 3, 2016), directed re-investigation, and ultimately found probable cause remained. He pleaded not guilty upon arraignment.
- At the close of the prosecution’s evidence, petitioner moved for dismissal on demurrer; the RTC denied the motion (March 21, 2017). Trial proceeded.
- Underlying Relationship and Alleged Acts
- Petitioner married AAA on December 29, 2006, and they had one daughter, BBB. AAA later worked abroad (Singapore).
- In mid-2015, AAA learned petitioner had a romantic relationship with CCC, who became pregnant by him. Text exchanges from CCC and petitioner to AAA evidenced humiliation, ridicule, and marital infidelity.
- Petitioner allegedly brought CCC to their hometown and cohabited with her, prompting AAA to return and seek DSWD assistance to recover BBB. BBB testified to emotional distress—crying in court—and expressed she no longer loved her father due to his affair and wished her parents would reconcile.
- Trial Court and Appellate Proceedings
- The RTC found petitioner guilty of psychological violence (emotional and psychological abandonment) under Section 5(i) of RA 9262; imposed an indeterminate sentence of 2 years, 4 months, 1 day of prision correccional minimum to 6 years, 1 day of prision mayor maximum, a P100,000 fine, and psychological counseling.
- On appeal (CA-G.R. CR No. 40971), the Court of Appeals affirmed with modification: increased the maximum to 8 years, 1 day of prision mayor. Petitioner’s motion for reconsideration was denied (October 18, 2019).
Issues:
- Whether the Court of Appeals erred in affirming the RTC’s conviction of petitioner for violation of Section 5(i) of RA 9262 based on psychological violence and emotional abandonment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)