Case Digest (G.R. No. 270257)
Facts:
In the case of G.R. No. 270257 decided on August 12, 2024, the petitioner XXX270257 was charged with and convicted of Psychological Violence under Section 5(i) of Republic Act No. 9262, the Anti-Violence against Women and Their Children Act. The complainant, private respondent AAA, was the legal wife of XXX270257; they were married on November 27, 1998, and had three children. The case arose from XXX270257's extramarital relationship with another woman, CCC, discovered in late 2016, leading to his abandonment of AAA and their children in January 2017. Despite a written agreement to sever ties with CCC and promises of financial support, XXX270257 failed to support his children adequately and openly cohabited with CCC, with whom he sired a child. AAA testified that these acts caused her emotional and mental anguish. XXX270257 denied cohabiting with CCC and claimed financial support by depositing PHP 5,000.00 monthly for his children, asserting that CCC was a mere acquaintance and ...Case Digest (G.R. No. 270257)
Facts:
- Parties and Marriage
- Petitioner XXX270257 and private complainant AAA were married on November 27, 1998.
- They have three children together.
- Discovery of Extramarital Affair
- On December 23, 2016, AAA discovered multiple calls from an unknown number on XXX270257's phone; a woman answered when AAA returned the call.
- On January 1, 2017, XXX270257 left their conjugal home and was discovered to be living with another woman, CCC.
- CCC declared in the presence of AAA and her children her intention to leave XXX270257 for the children's benefit, though this promise was not fulfilled.
- Attempts at Reconciliation and Further Developments
- Following efforts by XXX270257's relatives, AAA was convinced to desist from filing a case after XXX270257 promised to sever ties with CCC via a signed written agreement.
- Despite the agreement, XXX270257 continued cohabiting with CCC, moving her into his mother's adjacent house.
- XXX270257 and CCC had a child together, which he acknowledged as his own.
- XXX270257 did not provide sufficient financial support to AAA's children, leading AAA to file a complaint for psychological violence under Section 5(i) of Republic Act No. 9262.
- Trial and Lower Court Proceedings
- Upon arraignment, XXX270257 pleaded "Not Guilty."
- The Regional Trial Court (RTC) found all elements of psychological violence proven beyond reasonable doubt and convicted XXX270257.
- The RTC sentenced him to an indeterminate penalty of four years and two months to ten years imprisonment, a fine of Php200,000, and mandatory psychological treatment.
- The Court of Appeals (CA) affirmed the RTC judgment in toto.
- Petitioner’s Arguments on Appeal
- Petitioner argued that a psychological evaluation by an expert witness is indispensable to prove psychological violence.
- He contended that the psychological expert was not listed as a witness, thus violating due process.
- He also claimed the psychological evaluation was conducted too early (22 months before trial) to be relevant.
Issues:
- Whether the Court of Appeals erred in finding petitioner XXX270257 guilty beyond reasonable doubt of psychological violence under Section 5(i) of Republic Act No. 9262.
- Whether a psychological evaluation or expert testimony is indispensable in proving psychological violence.
- Whether the petitioner’s right to due process was violated by the admission of the psychological evaluation and expert testimony despite non-listing.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)