Philippine courts may exercise jurisdiction over a charge of psychological violence under Section 5(i) of R.A. No. 9262, even if the act causing such violence (e.g., marital infidelity) occurred outside the Philippines, provided that the victim, who is a resident of the Philippines, experienced the resulting mental or emotional anguish within the territorial jurisdiction of the Philippine court.

Petitioner AAA and respondent BBB were married in the Philippines and had two children. BBB started working in Singapore and later allegedly engaged in an extramarital affair there. AAA claimed this affair, along with other alleged abuses like lack of financial support and abandonment, caused her mental and emotional anguish while she was residing in Pasig City, Philippines.

• Petitioner AAA and respondent BBB were married on August 1, 2006, in Quezon City and had two children.
• In May 2007, BBB began working as a chef in Singapore, eventually acquiring permanent resident status there in September 2008.
• AAA resided with BBB's parents in Quezon City until March 2010, when she and her children moved to her parents' house in Pasig City.
• AAA alleged that BBB provided little to no financial support, compelling her to take on extra work. She also claimed virtual abandonment, mistreatment, and physical and sexual violence.
• BBB allegedly started an illicit relationship with Lisel Mok in Singapore.
• On April 19, 2011, AAA and BBB had a violent altercation in a hotel room in Singapore during AAA's visit with their children.
• An Information was filed charging BBB with causing AAA mental and emotional anguish through marital infidelity under Section 5(i) of R.A. No. 9262, with the offense allegedly committed on or about April 19, 2011, in Pasig City.
• The RTC initially found probable cause but later quashed the Information, ruling that the act causing the anguish (marital infidelity) occurred in Singapore, thus outside its territorial jurisdiction.

• AAA argued that mental and emotional anguish, an essential element of the offense under R.A. No. 9262, is experienced by her wherever she goes, including Pasig City where she resides, thus giving the RTC of Pasig City jurisdiction.
• AAA contended that Section 7 of R.A. No. 9262 allows the case to be filed where the crime or any of its elements was committed, at the option of the complainant.
• AAA posited that R.A. No. 9262 should be liberally construed to promote the protection and safety of victims, as stated in Section 4 of the Act.
• AAA warned that the RTC's ruling would render R.A. No. 9262 weak and ineffective, effectively licensing husbands of Filipino women to have extramarital affairs abroad without consequence.

• BBB argued that the acts complained of (marital infidelity) occurred in Singapore, outside the territorial jurisdiction of Philippine courts.
• BBB contended that the grant of the motion to quash was an acquittal and that only the civil aspect could be appealed by the private offended party.
• BBB claimed the petition should have been filed by the Office of the Solicitor General (OSG).
• BBB asserted that the petition was filed belatedly (this was found to be incorrect by the Supreme Court).

• Whether Philippine courts have territorial jurisdiction over a charge of psychological violence under R.A. No. 9262 when the act primarily causing the violence (marital infidelity) occurred outside the Philippines, but the resulting mental or emotional anguish was experienced by the victim in the Philippines.

• Yes, Philippine courts have jurisdiction. The Supreme Court granted AAA's petition, set aside the RTC's resolutions, and ordered the reinstatement of the Information.
• The Court held that psychological violence under Section 5(i) of R.A. No. 9262 criminalizes the psychological violence causing mental or emotional suffering on the wife, not marital infidelity per se.
• Mental or emotional anguish is an essential and distinct element of the offense, personal to the complainant.
• Section 7 of R.A. No. 9262 provides that the case may be filed where the crime or any of its elements was committed. Since mental or emotional anguish is an element, and AAA experienced this in Pasig City, the RTC of Pasig City has jurisdiction.
• The Court likened the offense to a transitory or continuing crime, where some acts material and essential to the crime occur in one territory while others occur in another. Jurisdiction lies in any court where an essential element of the crime was committed.
• For Philippine courts to have jurisdiction when the abusive conduct under Section 5(i) occurred outside Philippine territory, it is necessary that the victim be a resident of the place where the complaint is filed, as the anguish suffered is a material element of the offense.

• Territoriality of Criminal Law — Generally, criminal laws are binding only on persons and acts within the territory of the country. The RTC initially applied this strictly, stating the act causing anguish (infidelity) occurred in Singapore. The Supreme Court, however, found an exception by considering the location where an element of the crime (the resulting anguish) was consummated.
• Transitory or Continuing Crime — A crime where some acts material and essential to its commission occur in one municipality or territory, while others occur in another. In such cases, the court of any territory where an essential part of the crime was committed has jurisdiction. The Supreme Court applied this by analogy, stating that since the mental or emotional anguish (an element of psychological violence under RA 9262) was suffered by the victim in Pasig City, the Pasig RTC has jurisdiction even if the illicit relationship occurred abroad.
• Jurisdiction Determined by Allegations in the Information — The jurisdiction of a court over a criminal case is determined by the allegations in the complaint or information. The Information alleged that the mental and emotional anguish was caused in Pasig City.
• Elements of Psychological Violence under Section 5(i) of R.A. No. 9262 — The elements are: (1) The offended party is a woman and/or her child; (2) The woman is the wife or former wife, or in a sexual or dating relationship, or has a common child with the offender; (3) The offender causes mental or emotional anguish on the woman and/or child; and (4) The anguish is caused through acts like public ridicule, humiliation, repeated verbal/emotional abuse, denial of financial support, or similar acts (including marital infidelity as a means to inflict such anguish). The Court emphasized that mental or emotional anguish is the effect or damage sustained by the offended party and is an essential element.
• Liberal Construction of R.A. No. 9262 — Section 4 of R.A. No. 9262 mandates that the Act shall be liberally construed to promote the protection and safety of victims. This principle supported the Court's interpretation of venue and jurisdiction in favor of the victim.
• Venue in R.A. No. 9262 (Section 7) as Jurisdictional — Section 7 of R.A. No. 9262, which states that the case may be filed where the crime or any of its elements was committed, pertains to jurisdiction. The Court interpreted this to mean that if any element, including the resulting anguish, occurred in a particular place, the court of that place has jurisdiction.

• "Psychological violence is an element of violation of Section 5(i) just like the mental or emotional anguish caused on the victim. Psychological violence is the means employed by the perpetrator, while mental or emotional anguish is the effect caused to or the damage sustained by the offended party."
• "Contrary to the interpretation of the RTC, what R.A. No. 9262 criminalizes is not the marital infidelity per se but the psychological violence causing mental or emotional suffering on the wife."
• "The mental or emotional suffering of the victim is an essential and distinct element in the commission of the offense."
• "What may be gleaned from Section 7 of R.A. No. 9262 is that the law contemplates that acts of violence against women and their children may manifest as transitory or continuing crimes; meaning that some acts material and essential thereto and requisite in their consummation occur in one municipality or territory, while some occur in another."

• Morillo v. People of the Philippines — Referenced for allowing a private offended party to file a Rule 45 petition raising a pure question of law without OSG intervention when substantial justice requires; for differentiating dismissal from acquittal (dismissal for lack of territorial jurisdiction is not an acquittal and does not bar re-prosecution); and for reiterating that jurisdiction is determined by averments in the information and the law.
• Dinamling v. People — Cited for enumerating the elements of psychological violence under Section 5(i) of R.A. No. 9262, emphasizing that mental or emotional anguish is the effect caused to the victim.
• Treñas v. People — Cited for the fundamental rule that the place where the crime was committed determines venue and is an essential element of jurisdiction, and that jurisdiction is determined by allegations in the information.
• Tuzon v. Judge Cruz — Referenced by analogy for the principle of transitory or continuing offenses (specifically estafa), where damage is an element, and the case can be filed where damage was consummated, even if deceit occurred elsewhere. This supported the idea that anguish experienced in the Philippines confers jurisdiction.
• Del Socorro v. Van Wilsem — Cited for the principle that Rule 45 petitions raising only questions of law can be filed directly with the Supreme Court.
• Isip v. People — Cited within the Treñas reference regarding the determination of jurisdiction.
• People v. Salico — Cited within the Morillo reference regarding the distinction between dismissal and acquittal.

• Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004) — The primary law under which the respondent was charged.
• R.A. No. 9262, Section 3 (Definition of Terms) — Specifically, the definition of "Psychological violence" which includes acts causing mental or emotional suffering such as marital infidelity. This was crucial in identifying marital infidelity as a means to commit psychological violence.
• R.A. No. 9262, Section 4 (Construction) — States that the Act shall be liberally construed to promote the protection and safety of victims. This supported a broader interpretation of jurisdiction.
• R.A. No. 9262, Section 5(i) (Acts of Violence) — Defines the specific offense charged: "Causing mental or emotional anguish, public ridicule or humiliation to the woman or her child...". This section provided the elements of the crime.
• R.A. No. 9262, Section 7 (Venue) — Provides that the case may be filed where the crime or any of its elements was committed. The Court interpreted this section as pertaining to jurisdiction and foundational to its ruling that the Pasig RTC had jurisdiction because the element of anguish was experienced there.
• Rules of Court, Rule 45 (Appeal by Certiorari to the Supreme Court) — The procedural basis for AAA's petition to the Supreme Court, as it involved a pure question of law regarding jurisdiction.
• Rules of Court, Rule 65 (Certiorari, Prohibition and Mandamus) — Mentioned by the Court as the limited remedy against an acquittal, which was distinguished from the dismissal in this case.