This case involves a petition for review on certiorari challenging the Court of Appeals' decision which affirmed the Regional Trial Court's conviction of Jaime Araza for violating Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004). Araza was found guilty of committing psychological abuse against his wife, AAA, through marital infidelity, specifically by having an affair and begetting three illegitimate children with his paramour, which caused AAA emotional anguish and mental suffering. The Supreme Court denied the petition, affirming Araza's conviction but modifying the penalty and directing him to undergo mandatory psychological counseling.
Primary Holding
Marital infidelity, when it causes mental or emotional anguish to the wife, constitutes psychological violence under Section 5(i) of R.A. No. 9262, and the law does not require that the victim become psychologically ill but only that emotional anguish and mental suffering be proven, typically through the victim's testimony.
Background
The case arose from the marital relationship between Jaime Araza (petitioner) and AAA (private complainant), who were married in 1989. Their relationship deteriorated around February 2007 when Araza went to Zamboanga City for a networking business. AAA later discovered that Araza was having an affair with Tessie Luy Fabillar and had fathered three children with her. This discovery and Araza's subsequent actions led to AAA experiencing emotional and psychological distress, prompting her to file a criminal complaint.
History
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An Information for violation of R.A. No. 9262 was filed against Jaime Araza in the Regional Trial Court (RTC) of Las Pinas City, Branch 199, docketed as Criminal Case No. 15-1287.
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On October 30, 2017, the RTC rendered a Decision finding petitioner Jaime Araza guilty beyond reasonable doubt of violating Section 5(i) of R.A. No. 9262.
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Araza appealed the RTC's decision to the Court of Appeals (CA), docketed as CA-G.R. CR No. 40718.
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On December 17, 2018, the CA rendered a Decision affirming the RTC's decision in toto.
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Araza filed a motion for reconsideration, which was denied by the CA in its Resolution dated May 10, 2019.
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Araza filed a petition for review on certiorari before the Supreme Court.
Facts
- Jaime Araza and AAA were married on October 5, 1989. Their marriage was initially harmonious until Araza went to Zamboanga City in February 2007 for a networking business.
- AAA noticed a change in Araza's behavior; he appeared depressed, absent-minded, and anxious.
- On September 3, 2007, AAA confirmed that Araza was living with another woman, Tessie Luy Fabillar, in Zamboanga.
- AAA filed a complaint for concubinage, which was amicably settled with Araza and Fabillar agreeing not to see each other again.
- Araza returned to live with AAA but left again on November 22, 2007, without a word, and returned to his mistress.
- AAA received text messages, purportedly from Fabillar, about Araza being sick and needing money, and a threat to kill Araza.
- AAA, believing Araza was being restrained, filed a Petition for Habeas Corpus in June 2014, which was dismissed after an NBI investigation revealed Araza left on his own volition and had three children with Fabillar.
- The truth of Araza's infidelity and cohabitation caused AAA emotional and psychological suffering, including insomnia, asthma, depression, and hospitalization. She took anti-depressants and sleeping pills.
- Dr. Kristina Ruth Lindain, an expert witness, testified that AAA's symptoms (depressed mood, difficulty sleeping) were secondary to relational distress with Araza, though not sufficient to be considered a psychiatric disorder.
- Araza admitted to living with Fabillar since 2008 and acknowledged that their separation affected AAA emotionally and psychologically. He also admitted to signing an agreement to separate from Fabillar but continued living with her.
Arguments of the Petitioners
- The conviction was based on facts not alleged in the Information, specifically his alleged abandonment of the conjugal home and his pretenses that he was forcefully detained.
- The prosecution failed to prove beyond reasonable doubt the acts allegedly committed by him as constituting psychological violence under R.A. No. 9262.
- The prosecution failed to prove beyond reasonable doubt that AAA suffered mental and emotional anguish and that his act was the proximate cause thereof.
- He denied having an affair with Fabillar, claiming she was merely his guide in Zamboanga, and denied fathering children with her. He claimed he left AAA because he could no longer stand her attitude.
Arguments of the Respondents
- The elements of violation of Section 5(i) of R.A. No. 9262 were sufficiently alleged in the Information, specifically marital infidelity causing emotional anguish and mental suffering.
- The prosecution proved beyond reasonable doubt that Araza committed psychological violence upon AAA by committing marital infidelity (having an affair with Fabillar and begetting three children with her), which caused AAA to suffer emotional anguish and mental suffering.
- AAA's testimony regarding her suffering was credible and corroborated by Dr. Lindain's expert testimony.
- Araza's defense of denial cannot prevail over the positive declarations of the victim and his own admissions of cohabiting with Fabillar.
Issues
- Whether the Court of Appeals erred in affirming Araza's conviction for violation of Section 5(i) of R.A. No. 9262 although his conviction was based on facts allegedly not alleged in the Information.
- Whether the Court of Appeals erred in affirming Araza's conviction on the ground that the prosecution failed to prove beyond reasonable doubt the acts allegedly committed by Araza.
- Whether the Court of Appeals erred in affirming Araza's conviction, 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 Supreme Court denied the petition for lack of merit and affirmed Araza's conviction with modification as to penalty and additional directives.
- The Court found that the Information sufficiently alleged the elements of violation of Section 5(i) of R.A. No. 9262, specifically stating that Araza committed acts of psychological abuse by committing marital infidelity, having an affair with Tessie Luy Fabillar, and begetting three illegitimate children with her, thereby causing his wife emotional anguish and mental suffering.
- The Court ruled that the prosecution established Araza's guilt beyond reasonable doubt. Araza's marital infidelity, confirmed by AAA's testimony, his own admissions of living with Fabillar since 2008, and the birth of three children with her, constituted psychological violence.
- The Court held that AAA's testimony, supported by Dr. Lindain's expert opinion, sufficiently proved that she suffered mental and emotional anguish as a direct result of Araza's marital infidelity. The law only requires proof of such suffering, not necessarily a diagnosed psychiatric illness. Araza himself admitted knowing his separation from AAA affected her emotionally and psychologically.
Doctrines
- Sufficiency of Information — An Information is sufficient if it accurately and clearly alleges all the elements of the crime charged. The test is whether the material facts alleged will establish the essential elements of the offense as defined in the law. Applied here, the Court found the Information adequately stated the acts of marital infidelity and the resulting emotional anguish, fulfilling the elements of Section 5(i) of R.A. No. 9262.
- Psychological Violence under R.A. No. 9262 (Section 5(i)) — Refers to acts or omissions causing or likely to cause mental or emotional suffering of the victim, including mental infidelity. Section 5(i) specifically penalizes causing mental or emotional anguish, public ridicule or humiliation to the woman or her child through acts like repeated verbal and emotional abuse, denial of financial support, or similar acts or omissions. The Court affirmed that marital infidelity falls under "similar acts or omissions" and is a form of psychological violence if it causes the requisite anguish.
- Proof of Mental or Emotional Anguish — Jurisprudence requires only the testimony of the victim to establish mental or emotional anguish, as such experiences are personal. The law does not demand proof that the victim became psychologically ill. In this case, AAA's testimony detailing her depression, anxiety, insomnia, and need for medication, corroborated by Dr. Lindain, was deemed sufficient.
- Defense of Denial — The defense of denial is inherently weak and cannot prevail over positive and credible testimonies of prosecution witnesses, especially when the accused's denial is not supported by clear and convincing evidence. Araza's denial of infidelity was contradicted by his own admissions and AAA's consistent testimony.
- Indeterminate Sentence Law — This law governs the imposition of penalties. The minimum term is taken from the penalty next lower in degree, and the maximum term is that which could be properly imposed under the law, considering any modifying circumstances. The Court applied this law in determining Araza's penalty.
Key Excerpts
- "The law does not require proof that the victim became psychologically ill due to the psychological violence done by her abuser. Rather, the law only requires emotional anguish and mental suffering to be proven. To establish emotional anguish or mental suffering, jurisprudence only requires that the testimony of the victim to be presented in court, as such experiences are personal to this party."
- "Marital infidelity, which is a form of psychological violence, is the proximate cause of AAA's emotional anguish and mental suffering, to the point that even her health condition was adversely affected."
- "No doubt that the prosecution has successfully established that [Araza] left his wife AAA and decided to stay in Zamboanga City where he maintained an illicit affair with x x x Fabillar during the subsistence of their marriage. The record is brimming with evidence that [Araza] intentionally left AAA groping in the dark. Without any explanation or mature conversation with his wife, x x x [Araza] simply left his wife causing the latter emotional and psychological distress."
Precedents Cited
- Dela Chica v. Sandiganbayan — Cited to establish the standard for sufficiency of an Information: it must accurately and clearly allege all elements of the crime charged, enabling the accused to prepare a defense.
- Dimamling v. People — Cited for enumerating the elements of violation of Section 5(i) of R.A. No. 9262: (1) offended party is a woman/child; (2) woman is wife/former wife/has sexual/dating relationship/common child with offender; (3) offender causes mental/emotional anguish; (4) anguish is caused by public ridicule/humiliation, verbal/emotional abuse, denial of financial support/custody, or similar acts.
- Esteban Donato Reyes v. People — Referenced in relation to psychological violence being an indispensable element of Section 5(i) of R.A. No. 9262 and emotional anguish being personal to the complainant.
- Dinamling v. People (supra) — Also cited for the principle that to establish emotional anguish, the victim's testimony is sufficient as such experiences are personal.
- People v. Dizon — Cited for the principle that the trial court is in a better position to observe a witness's candor and behavior, and its assessment of credibility is respected unless substantial facts were overlooked.
- People v. Leonardo — Cited for the doctrine that the defense of denial is inherently weak and cannot prevail over positive and credible testimonies.
- People v. Peteluna, et al — Cited for the principle that denial, being a self-serving negative defense, cannot be given greater weight than the declaration of credible witnesses on affirmative matters.
Provisions
- Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004), Section 3(c) — Defines "Psychological violence" as acts or omissions causing or likely to cause mental or emotional suffering, including mental infidelity. This definition was crucial in establishing the nature of Araza's actions.
- Republic Act No. 9262, Section 5(i) — Penalizes causing mental or emotional anguish, public ridicule or humiliation to the woman or her child, including through repeated verbal and emotional abuse, denial of financial support, or similar acts. This is the specific provision Araza was charged under and found guilty of violating.
- Republic Act No. 9262, Section 6(f) — Prescribes the penalty of prision mayor for acts falling under Section 5(i). This section was used to determine the appropriate penalty for Araza.
- Revised Rules of Court, Rule 110, Section 6 — Requires that the information must state the acts or omissions complained of as constitutive of the offense. This rule was discussed in relation to the sufficiency of the Information against Araza.
- Revised Penal Code, Article 64 — Provides rules for the application of penalties, specifically paragraph 1, which states that when there are neither aggravating nor mitigating circumstances, the penalty prescribed by law shall be imposed in its medium period. This was applied in conjunction with the Indeterminate Sentence Law.