Case Digest (G.R. No. 252739)
Facts:
XXX, Petitioner, v. People of the Philippines, Respondent, G.R. No. 252739, April 16, 2024, Supreme Court En Banc, Hernando, J., writing for the Court.Petitioner XXX (a married man) was charged by Information (Dec. 29, 2016) with violating Section 5(i) of Republic Act No. 9262 (Anti‑Violence Against Women and Their Children Act of 2004) for “keeping a mistress, thereby causing upon complainant mental and emotional anguish.” The private complainant AAA is XXX’s wife; their marriage (1999) produced one child. The Information alleged that, on or before July 19, 2016, XXX kept a mistress and fathered a child with her, causing AAA anguish.
On trial AAA testified that in mid‑July 2016 she received messages and photos (via a third person, EEE) showing XXX’s family car at a Makati address and that a little boy there called XXX “Daddy.” AAA, her mother and family friend BBB went to the address on July 19, 2016; a confrontation followed, police and barangay officials intervened, and XXX admitted paternity of the child. AAA testified she suffered persistent distress (could not work or sleep for months). BBB corroborated AAA’s emotional breakdown and recounted that YYY (the woman) and the child said they had not been there long. XXX admitted siring the child but denied “keeping a mistress,” claiming a one‑night encounter in 2011 and limited visits thereafter.
On November 17, 2017, Branch 144, Regional Trial Court (RTC) convicted XXX of violating Sec. 5(i), finding the prosecution proved the elements (including that AAA suffered mental/emotional anguish caused by petitioner’s infidelity) and sentenced him to an indeterminate term with fine and mandatory counseling. On November 8, 2019 the Court of Appeals (CA) affirmed the RTC decision in CA...(Subscriber-Only)
Issues:
- Was petitioner XXX guilty beyond reasonable doubt of violating Section 5(i) of Republic Act No. 9262?
- Whether marital infidelity is a form of “psychological violence” under Sections 3(c) and 5(i) of RA 9262 and, if so, whether proof of the offender’s specific intent to cause mental or emotional anguish is required to sustain conviction when the mode of com...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)