Case Summary (G.R. No. 247429)
Factual Allegations in the Information
The Information charged that, beginning September 2007 in Las Piñas City, Araza wilfully committed acts of psychological abuse on his wife by engaging in a marital affair with Tessie Luy Fabillar and fathering three children with her, thus causing AAA emotional anguish and mental suffering.
Prosecution Evidence
AAA testified that:
• Her marriage to Araza (1989) was initially harmonious.
• In February 2007 he went to Zamboanga for business and became distant.
• She learned from friends that Araza was living with Fabillar; confirmed on September 3, 2007.
• She filed and settled a concubinage complaint, with written agreement to stay apart.
• Araza returned home briefly, then disappeared November 22, 2007, resuming cohabitation with Fabillar.
• She suffered insomnia, depression, asthma, and spent resources searching for him; medical certificates were presented (Exhs. E-E6).
Armando Que corroborated sightings of Araza and Fabillar together in Zamboanga.
Dr. Kristina Ruth Lindain, expert in psychiatry, opined that AAA’s symptoms (depressed mood, sleep difficulty) were secondary to relational distress and recommended counseling.
Defense Evidence
Araza denied an affair, attributing his return to Zamboanga to business and inability to bear AAA’s accusations. He admitted living with Fabillar since 2008 “under one roof” for one year but denied paternity of her children. He insisted AAA’s claims were motivated by her attitude and rumors.
RTC Findings and Ruling
The RTC credited AAA’s candid and consistent testimony. It held that:
1. Araza and AAA were lawfully married.
2. Psychological violence under Section 5(i) was established by proof of marital infidelity and abandonment.
3. AAA’s emotional anguish and mental suffering were proven through her testimony and Dr. Lindain’s expert opinion.
Denial was deemed a weak defense. Araza was convicted, sentenced under the Indeterminate Sentence Law to prision correccional (6 months + 1 day) to prision mayor (8 years + 1 day), fined ₱100,000, and ordered to indemnify moral damages of ₱25,000.
Court of Appeals Ruling
The CA affirmed the RTC, emphasizing that:
• R.A. 9262 punishes psychological violence causing mental suffering, not fidelity per se.
• Acts of infidelity and false pretenses of detention were proven.
• Prosecution witnesses were credible; defense denial lacked clear and convincing evidence.
Supreme Court Analysis on Sufficiency of the Information
Invoking Dela Chica v. Sandiganbayan and Rule 110, Section 6(1), the Court held that the Information need only allege material facts constituting each element of Section 5(i). The Information sufficiently stated:
• Offended party (AAA) is the wife of the offender (Araza).
• Emotional anguish and mental suffering were caused.
• Araza committed marital infidelity and fathered illegitimate children.
Supreme Court Analysis on Proof of Psychological Violence
Section 3(c) defines “psychological violence” and Section 5(i) penalizes acts causing mental anguish. In Dimamling v. People, elements are:
1. Offended party is a woman.
2. She is wife or in a sexual relationship.
3. Offender causes mental or emotional anguish.
4. Anguish arises from acts like repeated verbal abuse, humiliation, denial of support or similar acts.
AA
Case Syllabus (G.R. No. 247429)
Antecedents and Petition
- Petitioner Jaime Araza y Jarupay filed a petition for review on certiorari before the Supreme Court
- He sought reversal of the Court of Appeals Decision dated December 17, 2018 and its Resolution of May 10, 2019
- The Court of Appeals had affirmed the October 30, 2017 Decision of the Regional Trial Court of Las Piñas City, Branch 199, in Criminal Case No. 15-1287
- The RTC found petitioner guilty of violating Republic Act No. 9262, the Anti-Violence Against Women and Their Children Act of 2004
Information and Charge
- Information alleged that in or about September 2007 in Las Piñas City, petitioner intentionally humiliated and degraded his lawful wife AAA
- He was charged with psychological abuse by committing marital infidelity with Tessie Luy Fabillar and begetting three illegitimate children
- The acts were alleged to have caused emotional anguish and mental suffering to his wife
- Upon arraignment, petitioner pleaded not guilty
Prosecution Evidence
- Private complainant AAA testified that she married petitioner in October 1989 and that their marriage was initially harmonious
- She recounted petitioner’s change in behavior after February 2007, his depression, absentee-mindedness, and unexplained silence
- AAA received text messages alleging an affair, went to Zamboanga on September 3, 2007, and confirmed petitioner was living with Fabillar
- She filed a concubinage complaint, which was settled by agreement that petitioner and Fabillar would no longer see each other
- Petitioner left AAA again on November 22, 2007 and resumed cohabitation with Fabillar, leading AAA to file a petition for habeas corpus
- NBI investigation revealed petitioner left of his own volition and had three children with Fabillar
- AAA suffered insomnia, asthma, depression, and spent substantial amounts searching for petitioner
- Armando Que, a friend, testified that he observed petitioner and Fabillar together in Zamboanga holding hands
- Dr. Kristina Ruth Lindain, an expert witness, assessed AAA in September 2016 and opined that her depressed mood and sleep difficulties were secondary to relational distress, though not amounting to a psychiatric disorder, and recommended counseling
Defense Evidence
- Petitioner testified that he and AAA were married in 1989 and that he worked as an OFW and taxi driver
- He claimed to have assisted in AAA’s direct-sell