XXX270257 v. People of the Philippines
REITERATIONFacts
The Antecedents: Petitioner XXX270257 was married to private complainant AAA, with whom he had three children. AAA discovered XXX270257's extramarital affair with CCC. XXX270257 abandoned their conjugal home on January 1, 2017, and began living with CCC. Despite a written agreement to sever ties with CCC and promises to AAA, XXX270257 continued to cohabit with CCC in a house adjacent to their residence, eventually fathering a child with her. XXX270257 failed to provide financial support to his children with AAA. Procedural History: The prosecution filed an Information against XXX270257 for violation of Section 5(i) of Republic Act No. 9262. The Regional Trial Court (RTC) found XXX270257 guilty beyond reasonable doubt and sentenced him to suffer an indeterminate penalty, pay a fine, and undergo mandatory psychological counseling. The Court of Appeals (CA) affirmed the RTC's decision in toto. The Supreme Court received the case via a Petition for Review on Certiorari. The Petition: Petitioner XXX270257 assailed the CA's decision, arguing that independent evidence in the form of a psychological evaluation was needed to support a finding of psychological violence. He contended that the prosecution failed to list the psychologist as a witness and that the psychological report was not reserved as evidence, violating his right to due process.
Issue(s)
Whether the Court of Appeals erred in finding XXX270257 guilty of violation of Republic Act No. 9262. Whether a psychological evaluation is indispensable to prove psychological violence under Republic Act No. 9262.
Ruling
The Supreme Court denied the petition for review on certiorari, affirming the decision of the Court of Appeals with modification. Petitioner XXX270257 was found guilty beyond reasonable doubt of violation of Section 5(i) of Republic Act No. 9262. He was sentenced to suffer the indeterminate penalty of six months and one day of prision correccional, as minimum, to eight years and one day of prision mayor, as maximum, and ordered to pay a fine of PHP 200,000.00. He was also ordered to pay AAA moral damages in the amount of PHP 75,000.00 and to undergo mandatory psychological counseling or psychiatric treatment.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in finding XXX270257 guilty of violation of Republic Act No. 9262: The Court found that all the elements of Psychological Violence under Section 5(i) of Republic Act No. 9262 were present. It is undisputed that AAA is a woman married to XXX270257. The Court found that XXX270257 caused AAA mental and emotional anguish through his acts of engaging in an extramarital relationship, abandoning his wife and children, cohabiting with another woman (CCC) in full view of his family, siring an illegitimate child with CCC, and flaunting the affair on social media. The Court emphasized that the positive and categorical testimony of the victim prevails over the bare denial of the accused, and that XXX270257's defenses were flimsy and incredible. The Court also noted that the prosecution sufficiently adduced proof through AAA's testimony that she suffered mental and emotional anguish due to XXX270257's actions. The Court applied Section 6 of Republic Act No. 9262, which mandates imprisonment of prision mayor for acts falling under Section 5(i). Applying the Indeterminate Sentence Law, the Court imposed an indeterminate penalty of six months and one day of prision correccional as minimum, to eight years and one day of prision mayor as maximum. The Court also awarded moral damages of PHP 75,000.00 to AAA, considering the deep and repeated emotional anguish and stress suffered by the victim, and directed XXX270257 to pay a fine of PHP 200,000.00 and undergo mandatory psychological counseling or psychiatric treatment. On the issue of whether a psychological evaluation is indispensable to prove psychological violence under Republic Act No. 9262: The Court held that a psychological evaluation is not indispensable. Citing Labrador v. People and Araza v. People, the Court reiterated that the victim's testimony in court is sufficient to prove the element of emotional anguish and mental suffering. The law only requires emotional anguish and mental suffering to be proven, not necessarily that the victim became psychologically ill. Petitioner's insistence on the necessity of a psychological report has no basis in law and jurisprudence.
Main Doctrine
The Court affirmed that psychological violence under Section 5(i) of Republic Act No. 9262 does not require a psychological evaluation to prove emotional anguish; the victim's testimony is sufficient. Furthermore, the Court reiterated that marital infidelity, when flaunted and done with the intent to cause emotional anguish, public ridicule, or humiliation, constitutes psychological violence under the said law. The penalty imposed must adhere to the Indeterminate Sentence Law, and moral damages may be awarded to compensate for the emotional suffering of the victim.