Araza v. People
REITERATIONFacts
The Antecedents: Petitioner Jaime Araza y Jarupay (Araza) was charged with violating Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004) for allegedly committing psychological abuse upon his wife, AAA, by committing marital infidelity, having an affair with Tessie Luy Fabillar, and begetting three illegitimate children with her, thereby causing AAA emotional anguish and mental suffering. Procedural History: The Regional Trial Court (RTC) of Las Pinas City, Branch 199, found Araza guilty beyond reasonable doubt of violating Section 5(i) of R.A. No. 9262. The Court of Appeals (CA) affirmed the RTC's decision, denying Araza's appeal and subsequent motion for reconsideration. The Petition: Araza filed a petition for review on certiorari, assailing the CA's decision and resolution, arguing that his conviction was based on facts not alleged in the Information, that the prosecution failed to prove the acts allegedly committed by him, and that the prosecution failed to prove beyond reasonable doubt that AAA suffered mental and emotional anguish and that his acts were the proximate cause thereof.
Issue(s)
Whether the CA erred in affirming Araza's conviction for violation of Section 5(i) of R.A. No. 9262 although his conviction was based on facts not alleged in the Information. Whether the CA gravely erred in affirming Araza's conviction for violation of Section 5(i) of R.A. No. 9262 on the ground that the prosecution failed to prove beyond reasonable doubt the acts allegedly committed by Araza. Whether the CA gravely erred in affirming Araza's conviction for violation of Section 5(i) of R.A. No. 9262, considering that the prosecution failed to prove beyond reasonable doubt that AAA suffered mental and emotional anguish and Araza's act was the proximate cause thereof.
Ruling
The petition is denied for lack of merit. The Supreme Court affirmed the decision of the Court of Appeals, finding petitioner Jaime Araza y Jarupay guilty beyond reasonable doubt of violating Section 5(i) of Republic Act No. 9262. The Court imposed an indeterminate penalty of 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, a fine of P100,000.00, and ordered the payment of P25,000.00 as moral damages. Petitioner was also directed to undergo mandatory psychological counseling or psychiatric treatment.
Ratio Decidendi
On Whether the CA erred in affirming Araza's conviction for violation of Section 5(i) of R.A. No. 9262 although his conviction was based on facts not alleged in the Information: The Supreme Court ruled that the Information was sufficient. While Araza argued he could not be convicted for acts of abandonment or pretenses of detention not alleged, the Court found that the Information clearly stated the essential elements of the crime: that AAA is the wife of Araza, that AAA sustained emotional anguish and mental suffering, and that such anguish and suffering were inflicted by Araza through his extramarital affair with Fabillar and the begetting of three illegitimate children with her. The Court reiterated that an Information is sufficient if it accurately and clearly alleges all the elements of the crime charged, enabling the accused to prepare his defense. The acts of marital infidelity and its consequences, as alleged, were sufficient to constitute psychological violence under Section 5(i) of R.A. No. 9262. On Whether the CA gravely erred in affirming Araza's conviction for violation of Section 5(i) of R.A. No. 9262 on the ground that the prosecution failed to prove beyond reasonable doubt the acts allegedly committed by Araza: The Supreme Court found that the prosecution sufficiently established Araza's guilt beyond reasonable doubt. The Court relied on the credible and sincere testimony of AAA, who confirmed Araza's affair with Fabillar, their cohabitation, and the subsequent agreement to separate, which Araza violated. Araza himself admitted to living with Fabillar, even stating he was still staying with her at the time of his testimony. The Court found his defense of denial weak and unsubstantiated compared to the positive declarations of the victim and his own admissions. On Whether the CA gravely erred in affirming Araza's conviction for violation of Section 5(i) of R.A. No. 9262, considering that the prosecution failed to prove beyond reasonable doubt that AAA suffered mental and emotional anguish and Araza's act was the proximate cause thereof: The Supreme Court held that the prosecution successfully proved that AAA suffered mental and emotional anguish. AAA's testimony was categorical, detailing her depression, insomnia, and hospitalization due to Araza's marital infidelity. The expert testimony of Dr. Lindain corroborated that AAA's symptoms were secondary to relational distress with Araza, stemming from his absence and the circumstances of their separation. The Court emphasized that psychological violence is the means, and emotional anguish or mental suffering are the effects, and proof of the victim's testimony is sufficient to establish these effects, as they are personal experiences.
Main Doctrine
Marital infidelity, when it causes mental or emotional anguish and suffering to the wife, constitutes psychological violence under Section 5(i) of Republic Act No. 9262, and the Information is sufficient if it alleges the acts constituting marital infidelity and the resulting emotional anguish and mental suffering.