Case Digest (G.R. No. 270257)
Facts:
XXX270257 v. People of the Philippines and AAA, G.R. No. 270257, August 12, 2024, the Supreme Court Third Division, Inting, J., writing for the Court.Petitioner XXX270257 was charged by Information with violating Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act) before the Regional Trial Court (RTC), La Trinidad, Benguet, in Criminal Case No. 18-CR-12464. He pleaded not guilty and stood trial. The Information alleged that beginning January 1, 2017, and on other days, petitioner abandoned his wife AAA and their children, lived with another woman (CCC), sired a child with CCC, and intentionally denied marital love, affection and financial support, thereby causing mental and emotional anguish to AAA and their children.
At trial the prosecution presented AAA and their daughter BBB, who testified about petitioner’s extramarital conduct, cohabitation with CCC next door, social-media publicity of the relationship, and failure to adequately support AAA’s children. Petitioner denied cohabitation and the paternity of CCC’s child, claimed CCC was an acquaintance, asserted he opened accounts for his children and provided monthly support, and said he had filed (and later withdrew) an annulment case. AAA underwent psychological evaluation and later received therapy; the prosecution relied on her testimony (and, according to portions of the record, a psychological expert) to prove emotional anguish.
The RTC (Judge Marietta S. Brawner‑Cualing) convicted petitioner on July 3, 2020, of violating Section 5(i) of RA 9262, sentenced him to an indeterminate term of four years and two months prision correccional (minimum) to ten years prision mayor (maximum), imposed a PHP 200,000 fine, and ordered mandatory psychological counseling. Petitioner appealed to the Court of Appeals (CA), Seventh Division (Decision penned by Associate Justice Marlene Gonzales‑Sison), which, in a Decision dated February 8, 2023, affirmed the RTC judgment in toto; the CA denied petitioner’s motion for reconsideration in a Resolution dated September 6, 2023.
Petitioner filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, arguing principally that the prosecution’s failure to list or formally present the psychologist and her report violated his right to due process and...(Pro-only)
Issues:
- Did the presentation (or non‑presentation) of a psychological evaluator and psychological report, and the prosecution’s failure to list such witness, constitute a violation of petitioner’s right to due process that would overturn the conviction?
- Were the elements of Psychological Violence under Section 5(i) of RA 9262 proven beyond reasonable doubt so as to ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)