Case Digest (G.R. No. 252739) Core Legal Reasoning Model
Facts:
In the case of XXX v. People of the Philippines (G.R. No. 252739, April 16, 2024), the petitioner, referred to as XXX, was charged with a violation of Section 5(i) of Republic Act No. 9262, the Anti-Violence Against Women and Their Children Act of 2004, for causing mental and emotional anguish on his wife AAA through marital infidelity. XXX and AAA were married on February 11, 1999, and have one child. Due to XXX's work at the Bureau of Customs in Manila, he stayed in Manila during weekdays and came home to Tarlac on weekends.
In July 2016, AAA was informed by a co-worker about XXX's alleged affair with a woman named YYY and the existence of a four-year-old child from the affair. Upon verification with barangay authorities in Makati City, AAA found XXX and the alleged mistress at the latter’s residence, confirming the infidelity. Subsequently, XXX admitted fathering a child with YYY. The incident caused AAA significant psychological and emotional distress; she was unabl
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Case Digest (G.R. No. 252739) Expanded Legal Reasoning Model
Facts:
- Parties and background
- XXX (petitioner) and AAA (private complainant) were legally married in 1999 and have one son.
- XXX worked in Manila while their residence was in Tarlac; he stayed in Sampaloc (Manila) on weekdays and went home on weekends.
- Incident details
- On July 16, 2016, AAA was informed by a co-worker about photos and messages from EEE alleging XXX kept a mistress, YYY, with whom he has a four-year-old son.
- AAA confronted XXX, felt emotional anguish, and sought assistance to catch him in the act. On July 19, 2016, AAA, her mother, and friend BBB found XXX with YYY and the child in Makati.
- Police intervened during the confrontation, and XXX admitted paternity of the child.
- Subsequent events involved XXX threatening self-harm, locking himself in the bathroom, and eventual estrangement from AAA.
- AAA experienced severe emotional distress, unable to work or sleep for months after the incident.
- BBB corroborated AAA’s emotional state and related details of marital infidelity and cohabitation.
- Charges and trial court ruling
- XXX was charged with violating Section 5(i), Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act) for causing mental and emotional anguish through “keeping a mistress.”
- RTC found XXX guilty, citing his admitted paternity of the child and AAA’s visible anguish as evidence.
- XXX received an indeterminate sentence from prision correccional to prision mayor, a fine of PHP 100,000, and mandatory psychological counseling.
- Appeals
- The Court of Appeals (CA) affirmed the RTC decision and denied XXX’s motion for reconsideration.
- XXX filed a Petition for Review with the Supreme Court contesting his conviction.
Issues:
- Whether XXX is guilty of violating Section 5(i) of Republic Act No. 9262 for committing marital infidelity that caused mental or emotional anguish to AAA.
- Whether the prosecution proved beyond reasonable doubt the elements of psychological violence, including the intent to cause such mental or emotional anguish by marital infidelity.
- Whether marital infidelity per se constitutes psychological violence punishable under Republic Act No. 9262 or if specific intent to cause mental or emotional anguish must be established.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)