G.R. No. 229762 - AAA vs. People

Case Summary (G.R. No. 229762)

Evidence for the Prosecution

Private complainant BBB testified that she and petitioner were married for nineteen years and had two children, one of whom was CCC. Petitioner worked abroad and remitted money; from such support BBB purchased household items including a television, refrigerator, karaoke, washing machine, dining table and bed. On February 17, 2010 the couple argued about debts incurred by BBB for which the television and refrigerator were used as collateral. Petitioner hauled the TV, refrigerator, divider, bed and dining table to his parents’ house; BBB attempted to stop him and alleged that petitioner “mauled” her. CCC corroborated that she saw her parents arguing and subsequently saw petitioner removing appliances and furniture.

Evidence for the Defense

Petitioner testified that BBB incurred debts with lenders and neighbors without his knowledge or consent and that the television and refrigerator had been offered as collateral. He claimed he removed the appliances and some furniture to his parents’ house to safeguard them from an impending sheriff seizure; he admitted that BBB blocked the door and that he pushed her aside. He maintained the items were acquired through his labor and that he did not intend to inflict emotional harm.

RTC Decision

The RTC found that all elements of the offense under Section 5(i) of R.A. No. 9262 were present: the victim was a woman and petitioner was her husband; petitioner caused mental or emotional anguish; and such anguish resulted from acts within the scope of Section 5(i). The RTC credited BBB’s testimony that she was humiliated, hurt and physically mauled while petitioner removed conjugal properties against her will, and discredited petitioner’s protective‑motive defense as uncorroborated. The RTC convicted petitioner and imposed an indeterminate penalty of six months and one day of prision correccional to eight years and one day of prision mayor.

Court of Appeals Ruling

The CA affirmed the RTC’s factual findings and conclusion that the prosecution established the elements of Section 5(i), particularly mental or emotional anguish as shown by the victim’s testimony. The CA, however, found passion and obfuscation as a mitigating circumstance given petitioner’s emotional outburst upon discovering the debts and applied that mitigation to reduce the maximum of the term, resulting in an indeterminate penalty of six months and one day of prision correccional to six years and one day of prision mayor. The CA denied petitioner’s motion for reconsideration.

Issues Raised on Review

Petitioner presented two issues to the Supreme Court: (1) whether the prosecution overthrew his constitutional presumption of innocence; and (2) whether petitioner’s acts constituted emotional and psychological abuse under Section 5(i) of R.A. No. 9262.

Petitioner’s Arguments

Petitioner contended that he removed the property only to protect it from creditors, did not intend to cause emotional pain, did not deprive his wife of use of the property, and did not inflict emotional violence. He argued BBB’s testimony was insufficiently detailed to prove psychological violence and maintained the presumption of innocence remained intact.

Government’s Position (Office of the Solicitor General)

The OSG maintained that BBB testified candidly about mental and emotional anguish, humiliation and verbal abuse in the presence of the children. The OSG further asserted that good faith and absence of criminal intent are not valid defenses under R.A. No. 9262, a special law.

Legal Elements and Standard Applied

The Court reiterated the elements for conviction under Section 5(i) (as stated in Dinamling v. People): (1) the offended party is a woman and/or her child; (2) the relationship criteria (wife, former wife, sexual/dating relationship or common child) are met; (3) the offender causes mental or emotional anguish; and (4) the anguish is caused through acts enumerated in Section 5(i) (public ridicule/humiliation, repeated verbal/emotional abuse, denial of financial support or custody/access or similar acts). Psychological violence under R.A. No. 9262 refers to acts or omissions likely to cause mental or emotional suffering; the victim’s testimony is necessary to prove mental or emotional anguish because such experiences are personal.

Application of Law to Facts — Mental and Emotional Anguish

The Court found BBB’s testimony and corroborating statements sufficient to establish mental and emotional anguish: BBB recounted being “mauled,” verbally abused, put to shame, and deprived of conjugal items (TV, refrigerator, divider, bed, dining table), and expressed feelings of hurt, confusion and humiliation in front of her children. CCC’s testimony that similar arguments and physical abuse had occurred was also considered corroborative. The deprivation of use of conjugal property and the attendant conduct caused anguish within the meaning of Section 5(i). Accordingly, the prosecution proved the elements beyond reasonable doubt, overcoming the presumption of innocence (moral certainty standard).

Mitigating Circumstance — Passion and Obfuscation

The Court disagreed with the CA’s application of passion and obfuscation as a mitigating circumstance. To invoke that mitigation, there must be (1) an unlawful act by another sufficient to produce the mental state of obfuscatio

Case Syllabus (G.R. No. 229762)

Citation and Court

Reported at 844 Phil. 213; 115 OG No. 43, 11960 (October 28, 2019).
Decided by the Supreme Court, Third Division, G.R. No. 229762, November 28, 2018 (Resolution penned by Justice Gesmundo).
Case originated from Criminal Case No. II-14837, Regional Trial Court (RTC), Iligan City, Branch 2.
Court of Appeals (CA) decision: July 22, 2016 (CA-G.R. CR No. 01170-MIN); CA resolution denying reconsideration: January 12, 2017.
Petition for review on certiorari filed by petitioner AAA seeking reversal of the CA decision and resolution.

Parties and Identity Protections

Petitioner: Referred to in the record as "AAA" (fictitious initials used in conformity with Administrative Circular No. 83-2015).
Private complainant (victim): Referred to as "BBB" (fictitious initials).
Child-witness: Referred to as "CCC" (fictitious initials).
City name where the alleged acts occurred is blotted pursuant to Administrative Circular No. 83-2015 to protect identity of the victim.
Identity confidentiality is mandated by various statutes cited in the record, including R.A. Nos. 7610, 8505, 9208, 9262, and 9344.

Information / Charge

Information alleges that on or about February 17, 2010, in the City of [XXX], Philippines, petitioner willfully, unlawfully and feloniously committed acts of violence against his wife, BBB, by taking their conjugal properties and bringing them to the house of his mother without regard to her feelings and against her will, which caused mental and emotional anguish to BBB.
Charged as violation of Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004).
Upon arraignment petitioner pleaded not guilty.

Evidence for the Prosecution (Summary of Witness Testimony)

Prosecution presented two witnesses: BBB (private complainant) and CCC (complainant’s daughter).
BBB’s background testimony:
- Married to petitioner for 19 years; they had two children.
- Petitioner worked abroad; BBB was a full-time housewife.
- Petitioner sent money which BBB used to buy household items: television set, refrigerator, karaoke, washing machine, dining table, and a "sleeprite" bed.
- Family lived in a house owned by petitioner’s mother; petitioner’s parents lived in a separate house in the same city.
Events of February 17, 2010 (BBB’s testimony):
- A heated argument occurred regarding BBB’s supposed indebtedness where the television and refrigerator were used as collateral.
- BBB explained she incurred debt to pay her siblings money borrowed in relation to petitioner’s applications for work.
- Petitioner hauled the television set, refrigerator, divider, "sleeprite" bed, and dining table to his parents’ house.
- BBB attempted to stop petitioner but was "mauled" by him.
- BBB testified she was "so hurt," "confused," and "put into shamed," and that the children were present.
- BBB identified the items taken: TV, refrigerator, divider, Sleep Rite (bed), dining table.
CCC’s testimony:
- Witnessed parents arguing but did not know the subject of the argument.
- Saw petitioner removing several appliances and furniture from the house.
Portions of BBB’s testimony were quoted in the record and cited in the RTC and CA decisions.

Evidence for the Defense (Summary of Petitioner’s Testimony)

Petitioner testified as sole defense witness.
Petitioner’s account:
- Claimed BBB incurred debts from a lending institution and from neighbors without his knowledge or approval.
- Television set and refrigerator were used as collateral for those loans.
- Petitioner removed appliances and some furniture to his parents’ house for safety, because a debt collector warned that the sheriff would confiscate them the following day.
- While taking out the items, BBB blocked the door; petitioner pushed her aside in anger.
- Petitioner asserted household items were acquired through his hard work and denied knowledge why BBB incurred debts when he regularly sent support.
Petitioner denied intent to cause emotional pain and claimed protective rationale for removing items.

Ruling of the Regional Trial Court (RTC)

RTC found all elements of the offense under Section 5(i) of R.A. No. 9262 satisfied.
RTC findings emphasized:
- Marriage of the parties established the relationship element.
- Petitioner’s act of taking conjugal properties over his wife’s objections and physically harming and verbally abusing her constituted violence under Section 5(i).
- Petitioner’s claim of protecting property was uncorroborated and unjustified.
- RTC described the private complainant as "so hurt and humiliated" and noted petitioner "abandoned her and their children."
Dispositive portion (RTC sentence):
- Found accused AAA guilty beyond reasonable doubt of violation of Section 5(i) of R.A. No. 9262.
- Indeterminate penalty imposed: six (6) months and one (1) day of prision correccional as minimum to eight (8) years and one (1) day of prision mayor as maximum.

Ruling of the Court of Appeals (CA)

CA affirmed RTC’s factual findings and conviction for violation of Section 5(i) of R.A. No. 9262.
CA’s reasoning and findings:
- Prosecution sufficiently established the statutory elements, including mental or emotional anguish.
- BBB’s testimony was highlighted as proof of mental or emotional anguish.
- CA found the mitigating circumstance of passion and obfuscation applicable:
  - Petitioner’s outburst was triggered by BBB’s incurring indebtedness without his knowledge or consent.
  - CA described petitioner’s reaction as a natural emotional response of a person who found that the fruits of his hard work were squandered.
- Based on mitigation, CA reduced the maximum of the indeterminate penalty.
CA fallo (modified sentence):
- Affirmed conviction but modified sentence to indeterminate penalty of six (6) months and one (1) day of prision correccional as minimum to six (6) years and one (1) day of prision mayor as maximum.
CA denied pe