Case Summary (G.R. No. 243049)
Factual Background
The private complainant, identified as AAA, testified that she and XXX were married on April 1, 1996, and had two children after roughly seventeen years of marriage. AAA recounted that their marriage deteriorated when she overheard XXX tell a cousin that he had been giving a weekly allowance of P1,000 to a woman named Jessiree Yana and had paid P37,000 for the operation of a woman identified as Rona Matchimura. When AAA confronted XXX and accused him of an extramarital affair and fathering a child with another woman, XXX denied the allegations, and a heated argument ensued. AAA called her brother, BBB, to remove XXX from the conjugal home, and the couple ceased living together thereafter. AAA alleged that XXX’s infidelity caused her emotional injury and led to their eldest child’s nervous breakdown. On June 6, 2013, AAA received a text message from XXX containing a threatening and abusive statement, whereupon she reported the matter to the police and sought a protection order, which the Metropolitan Trial Court in Cities granted on October 21, 2013.
Defense Version
XXX testified as the sole defense witness. He admitted marital difficulties but denied having an illicit relationship and contended that rumors of infidelity were unfounded. He stated that he left the conjugal home in 2013 and lived at a friend’s house. He further alleged that when charges were filed their eldest child suffered a nervous breakdown, which prompted AAA to execute an Affidavit of Desistance to refrain from pursuing the case for the child’s sake. On cross-examination, however, XXX admitted to acts of infidelity.
Trial Court Proceedings and Ruling
The Regional Trial Court, in a Decision dated February 24, 2016, found XXX guilty beyond reasonable doubt of violating Section 5(i) in relation to Section 6(f) of RA 9262. The RTC imposed an indeterminate term of imprisonment ranging from six months and one day of prision correccional as minimum, to six years and one day of prision mayor as maximum, and ordered a fine of P100,000. The RTC credited AAA’s testimony and demeanor, and BBB’s corroborative testimony, concluding that XXX’s infidelity caused mental and emotional suffering to AAA and contributed to their daughter’s nervous breakdown. The RTC also noted XXX’s admissions on cross-examination as corroborative.
Court of Appeals Ruling
On appeal, the Court of Appeals dismissed XXX’s appeal in its Decision dated January 24, 2018 and affirmed the RTC’s factual findings. The CA emphasized the rule that trial courts’ credibility determinations merit deference and found no reason to disturb the RTC’s assessment. The CA held that the prosecution established psychological violence under Section 5(i) by proving marital infidelity and the resulting emotional anguish. The CA also relied on XXX’s admission during cross-examination as a judicial admission that conclusively bound him.
Petition for Review and Procedural History Before the Supreme Court
XXX filed a Motion for Reconsideration in the CA, which the CA denied in a Resolution dated October 29, 2018. He then obtained an extension and filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court. The Supreme Court took up the petition on the record presented by the lower courts and the parties’ submissions.
Issues Presented
The principal issue was whether the prosecution proved beyond reasonable doubt the elements of psychological violence under Section 5(i) of RA 9262, specifically whether (1) mental or emotional anguish was caused to AAA and (2) such anguish resulted from acts enumerated under Section 5(i), including marital infidelity. A subsidiary issue was whether the trial courts erred in imposing the penalties ordered and whether additional penalties prescribed by Section 6(f) were properly imposed.
The Parties’ Contentions
The prosecution maintained that AAA’s testimony and BBB’s corroboration established that XXX’s marital infidelity caused mental and emotional anguish to AAA and their child, constituting psychological violence under RA 9262. XXX contended that the presumption of innocence remained intact, denied the alleged affair, and pointed to AAA’s purported Affidavit of Desistance and his own denials as creating reasonable doubt regarding guilt.
The Court’s Findings on Elements of the Offense
The Supreme Court affirmed that the first two statutory elements were present: the offended party was a woman and the woman was the wife of the offender. The Court applied the definition of psychological violence in Section 3(c) of RA 9262 and the elemental formulation from AAA v. People and Dinamling v. People, concluding that the prosecution proved that XXX’s acts constituted psychological violence and caused mental and emotional anguish. The Court emphasized that psychological violence is the means while mental or emotional anguish is the effect, and that testimony of the victim is necessary to establish anguish. The Court found AAA’s in-court demeanor and testimony credible and corroborated by BBB. The Court also rested on XXX’s judicial admission on cross-examination that he committed acts of infidelity as further proof of the offense.
Presumption of Innocence and Standard of Proof
The Court reiterated the constitutional presumption of innocence under Art. III, Sec. 14, 1987 Constitution and the requirement of proof beyond reasonable doubt, citing People v. Rodriguez and People v. Manson. The Court held that the presumption of innocence was overcome because the prosecution established every element of the offense to the degree of moral certainty required for criminal conviction.
Sentencing, Modification, and Remedial Orders
While the Supreme Court affirmed the conviction and the indeterminate term of imprisonment as imposed by the RTC and CA, it noted that both lower courts failed to order mandatory psychological counseling or psychiatric treatment, a penalty mandated by Section 6(f) of RA 9262 in addition to imprisonment and fine. The Court therefore affirmed the conviction with modification: the sentence remained an indeterminate term from six months and one day of prision correccional to six years and one day of prision mayor; the fine of P100,000 was affirmed; and the Court ordered XXX to undergo mandatory psycho
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Case Syllabus (G.R. No. 243049)
Parties and Procedural Posture
- XXX filed a Petition for Review on Certiorari under Rule 45 assailing the Court of Appeals Decision dated January 24, 2018 and Resolution dated October 29, 2018 in CA-G.R. CR No. 39608.
- People of the Philippines was the respondent in the criminal prosecution for violence against women and their children.
- The Regional Trial Court, Branch 39, convicted XXX of violating Section 5(i) in relation to Section 6(f) of RA 9262 and imposed imprisonment and a fine in a Decision dated February 24, 2016.
- The Court of Appeals affirmed the RTC Decision and denied the Motion for Reconsideration, after which XXX sought review before the Supreme Court within an extension granted in November–December 2018.
Key Factual Allegations
- AAA testified that she and XXX were married on April 1, 1996 and lived together for 17 years and that their marriage later deteriorated due to XXX's alleged extramarital relationship and a child with another woman.
- AAA averred that in February 2013 she overheard XXX state he gave weekly allowances to Jessiree Yana and paid P37,000.00 for the operation of Rona Matchimura, and that confrontation led to a heated quarrel and eventual separation.
- AAA testified that on June 6, 2013 XXX sent a threatening text which caused her to fear for her life and for her minor children and prompted her to report the incident to the police and seek a protection order.
- The defense presented XXX as the sole witness who denied the alleged affair but admitted that he left the conjugal home in 2013 and that his eldest child suffered a nervous breakdown, which led AAA to execute an affidavit of desistance.
- On cross-examination XXX admitted to having committed acts of infidelity, which the trial court treated as a judicial admission.
Charges and Statutory Framework
- The Information charged XXX with violation of Section 5(i) in relation to Section 6(f) of RA 9262, the Anti-Violence Against Women and Their Children Act of 2004.
- Section 5(i) penalizes causing mental or emotional anguish, public ridicule or humiliation, including repeated verbal and emotional abuse and denial of access to children.
- Section 3(c) of RA 9262 defines psychological violence to include acts or omissions causing mental or emotional suffering such as intimidation, harassment, public ridicule, repeated verbal abuse, and marital infidelity.
- Section 6(f) prescribes punishment by prision mayor, a fine of not less than One hundred thousand pesos (P100,000.00) but not more than Three hundred thousand pesos (P300,000.00), and mandatory psychological counseling or psychiatric treatment with reporting of compliance to the court.
Issues Presented
- Whether the prosecution proved beyond reasonable doubt that XXX committed psychological violence under Section 5(i) in relation to Section 6(f) of RA 9262.
- Whether the presumption of innocence protected XXX from conviction in the face of the prosecution's evidence.
- Whether the trial and appellate courts erred in failing to impose mandatory psychological counseling or psychiatric treatment as part of the penalty.
Trial Court Findings
- The RTC found that the prosecution proved beyond reasonable doubt that XXX caused mental and emotional suffering to AAA by reason of his infidelity and associated conduct.
- The RTC credited AAA's testimony and demeanor in open court and found corroboration in the testimony of her brother, BBB.
- The RTC relied on XXX's admission on cross-examination regarding infidelity as proof of the factual basis for psychological vi