XXX vs. People and AAA

Facts:

Petitioner XXX was charged by information with violating Section 5(i) of Republic Act No. 9262 (the Anti‑Violence Against Women and Their Children Act of 2004) for allegedly committing psychological violence on his wife, AAA, by marital infidelity (having a sexual relationship with PPP and fathering two children with her) that caused AAA mental or emotional anguish. When arraigned XXX pleaded not guilty. During pretrial the parties stipulated, among other things, that they were married, had a son (BBB), had been living separately since 2008, and that public records showed MMM and NNN listed XXX as father and PPP as mother.

At trial the prosecution presented AAA and Dr. Maria Carmen P. Lambuson, plus documentary exhibits: AAA’s sworn statement, Dr. Lambuson’s certification and psychiatric evaluation, social‑media printouts showing posts and photos of XXX with PPP and their children, marriage and birth certificates. AAA testified that petitioner repeatedly went out at night during her pregnancy, she found suggestive messages on his phone, he left the marital home the day after being confronted, and subsequently he flaunted his relationship and children with PPP on social media; Dr. Lambuson diagnosed AAA with dysthymia (chronic depression) and attributed its main precipitant to petitioner’s abandonment.

The defense offered XXX’s testimony, a psychological report by Dr. Visitacion G. Revita, and other documents. XXX contended the marriage soured because of AAA’s supposed immaturity and dependence on her family; he claimed he left after being told to do so by AAA’s mother, that he attempted reconciliation, and that AAA filed the case vindictively following a dispute over their son’s schooling.

The Regional Trial Court (RTC) rendered judgment of acquittal on September 30, 2016, finding the prosecution failed to prove guilt beyond reasonable doubt. The RTC relied on the belated filing of the complaint, AAA’s admissions that XXX continued to communicate with and support their son, and the delayed psychiatric consultation—factors which, in the RTC’s view, raised reasonable doubt as to psychological violence.

The Office of the Solicitor General (OSG) filed a petition for certiorari under Rule 65 with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC in acquitting XXX; the People argued marital infidelity falls within RA 9262’s definition of psychological violence. By Decision dated March 30, 2017 (Fifth Division, penned by Associate Justice Fernanda Lampas Peralta), the CA set aside the RTC acquittal, found XXX guilty of Section 5(i) RA 9262, imposed an indeterminate prison term and a P300,000 fine, and ordered counseling; the CA denied reconsideration by Resolution dated June 6, 2017.

XXX then filed a Petition for Review on Certiorari under Rule 45 with the Supreme Court seeking reinstatement of the RTC acquittal. The Supreme Court, after...(Pro-only)

Issues:

• Did the filing of a Rule 65 petition by the Office of the Solicitor General to assail the RTC’s acquittal violate petitioner XXX’s right against double jeopardy?
• Did the prosecution prove beyond reasonable doubt that petitioner XXX committed psychological violence under Section 5(i) of ...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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