Title
XXX70257 vs. People
Case
G.R. No. 270257
Decision Date
Aug 12, 2024
A man was found guilty of psychological violence against his wife after abandoning her for another woman, causing emotional anguish and failing to provide support for their children. The Supreme Court affirmed the penalty and damages awarded.
psychological violence
emotional anguish
infidelity
A

Case Summary (G.R. No. 87297)

Key Dates

Marriage of petitioner and AAA: November 27, 1998.
Discovery of unknown calls by AAA: December 23, 2016.
Petitioner left the conjugal home and allegedly began cohabiting with CCC: January 1, 2017 (with related events in early 2017, including a written promise/agreement dated March 1, 2017).
Psychological evaluation of AAA: April 21 and 25, 2017.
RTC Judgment convicting petitioner: July 3, 2020.
CA Decision affirming RTC: February 8, 2023.
CA Resolution denying reconsideration: September 6, 2023.
Supreme Court decision on petition: August 12, 2024.

Procedural Posture

Petitioner was charged by Information with violation of Section 5(i) of RA 9262 for allegedly causing psychological violence against his wife and their children by abandoning them, cohabiting with another woman (CCC), siring a child with CCC, publicly flaunting the relationship, and denying adequate financial support. The petitioner pleaded not guilty, was convicted by the RTC, had that conviction affirmed by the CA, and then filed a Petition for Review on Certiorari before the Supreme Court.

Facts Found by the Prosecution

AAA discovered unknown calls on the petitioner’s phone in December 2016 and confirmed a woman answered when she returned the call. On January 1, 2017, petitioner left the conjugal home and began living with CCC. CCC represented to AAA and the children that she would leave the petitioner for the children’s benefit, but the petitioner did not return. Petitioner and CCC cohabited in a house adjacent to AAA’s residence; petitioner and CCC later had a child which petitioner acknowledged. Petitioner allegedly failed to provide sufficient financial support to his children by AAA. AAA underwent therapy and a psychological evaluation and testified to mental and emotional anguish; their daughter BBB also testified.

Defense Version

Petitioner denied cohabitation with CCC, asserting she was an acquaintance who visited the ancestral house. He claimed to have filed (but later withdrawn) an annulment case against AAA. Regarding the child with CCC, petitioner claimed he merely “stood as the father” because he wanted a male child. He also asserted that he provided financial support by depositing funds in separate bank accounts for his minor children.

RTC Ruling (Trial Court)

The RTC found the prosecution proved beyond reasonable doubt the elements of psychological violence under Section 5(i) of RA 9262. The RTC relied on the positive and affirmative testimony of AAA and her daughter, finding petitioner’s denial to be weak and insufficient to overcome that evidence. The RTC convicted petitioner and imposed an indeterminate penalty of prision correccional in its medium period (minimum) to prision mayor in its medium period (maximum), a fine of PHP 200,000, and mandatory psychological counseling or psychiatric treatment.

Court of Appeals Ruling

The CA affirmed the RTC judgment in toto. The CA held that petitioner’s extramarital relationship, abandonment of his wife, siring an illegitimate child, and failure to financially support his children caused emotional anguish to AAA and the children, as evidenced by their testimonies. The CA denied the petitioner’s motion for reconsideration.

Issue Presented to the Supreme Court

Whether the Court of Appeals erred in affirming petitioner’s conviction under Section 5(i) of RA 9262 for psychological violence, especially considering petitioner’s contention that a psychological evaluation or expert testimony was indispensable and that the presentation of such evidence violated his right to due process because the psychologist and report were not properly listed as witnesses or reserved as evidence.

Petitioner's Arguments

Petitioner argued that: (1) independent expert evidence in the form of a psychological evaluation or assessment is necessary to substantiate a finding of psychological violence; (2) the prosecution did not list the psychologist or reserve the psychological report at trial, rendering any reliance on that evaluation improper; and (3) the psychological evaluation was conducted in April 2017, approximately 22 months before the pre-trial conference, and the late presentation therefore violated his right to due process.

Supreme Court’s Resolution — Standard of Review and Disposition

The Supreme Court denied the petition for lack of reversible error and affirmed the CA’s decision with modification as to the precise indeterminate penalty. The Court adopted the CA’s factual findings and legal reasoning that the elements of psychological violence under Section 5(i) were satisfied.

Elements of Section 5(i) and Application to the Case

The Court reiterated the elements derived from jurisprudence (citing Dinamling v. People): (1) the offended party is a woman and/or her child(ren); (2) the woman has the relevant relationship with the offender (wife, former wife, sexual or dating partner, or mother of a common child); (3) the offender causes mental or emotional anguish to the woman and/or child(ren); and (4) the anguish is caused through acts such as public ridicule or humiliation, repeated verbal and emotional abuse, denial of financial support, denial of custody or access, or similar acts or omissions. It was undisputed that AAA was petitioner’s wife; the Court focused on the third and fourth elements and found them satisfied by the testimony and surrounding facts.

On the Necessity of a Psychological Evaluation or Expert Testimony

The Court rejected petitioner’s claim that a psychological evaluation or expert testimony is indispensable. Citing Labrador v. People and Araza v. People, the Court held that neither RA 9262 nor jurisprudence requires proof of psychological illness or an expert psychological evaluation to establish emotional anguish; the victim’s own testimony is sufficient to establish emotional anguish or mental suffering because these experiences are personal to the victim. Accordingly, the absence of a psychological expert report did not undermine the conviction.

Credibility and Weight of Evidence

The Court emphasized the settled rule that a victim’s positive, categorical, and credible testimony outweighs the accused’s mere denial. The Court found petitioner’s defenses—denial of cohabitation, claim of acquaintance, assertion he merely “stood as the father,” and claimed financial deposits—were self-serving and insufficient to rebut the prosecution’s direct evidence. The Court accepted the CA’s summary that petitioner abandoned his family, cohabited publicly with CCC adjacent to AAA’s residence, sired and acknowledged a child by CCC, and publicly displayed the relationship on social media, acts that caused AAA and the children emotional anguish.

Penal Consequences and Modification of Penalty

The Court analyzed Section 6 of RA 9262 and applied the Indeterminate Sentence Law. Recognizing that acts under Section 5(i) are punishable by prision mayor (six years and one day to 12 years) and that, absent aggravating or mitigating circumstances, the maximum term is to be taken from prision mayor in its medium period (eight years and one day to 10 years), the Court set the indeterminate penalty as follows: minimum — six months and one day of prision correccional;

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