Caridaoan vs. People

Psychological violence under Section 5(i) of Republic Act No. 9262 is committed only upon proof beyond reasonable doubt that the offender willfully caused mental or emotional anguish through the charged acts with criminal intent to inflict such suffering and that the anguish was directly attributable thereto; distress incidental to the breakup of an intimate relationship does not by itself establish liability.

AAA and Caridaoan lived together without marriage beginning in 1998 and jointly operated a 24-hour car wash business in ZZZ City. AAA, who suffered from rheumatic heart disease, later hired Michelle as stay-in secretary for the business and to reside in their rented house. Republic Act No. 9262 penalizes violence against women and their children, including under Section 5(i) the causing of mental or emotional anguish, public ridicule or humiliation.

AAA and Caridaoan lived together without benefit of marriage since 1998 and put up a 24-hour car wash business. In November 2009 AAA hired Michelle as secretary to list customers, sell soft drinks and count daily income, with AAA and Caridaoan tending the shop by day and Michelle by night. Michelle also stayed in their rented house in ZZZ City, sleeping on the upper deck of a double-deck bed while AAA and Caridaoan occupied the lower deck.

According to the prosecution, in the first week of February 2010 AAA suspected an affair after seeing Michelle standing close between Caridaoan's open legs as he sat on the sofa watching television. On February 6, 2010, while AAA and Caridaoan quarreled in their car, Michelle called to say she was going home to Nueva Vizcaya and asked AAA to take care of Caridaoan, confirming AAA's suspicion. The next day, February 7, AAA went to the hotel where the two were staying and saw Caridaoan embrace Michelle, who said she could not go on without him; Caridaoan allegedly said he would be with Michelle in the daytime and with AAA at nighttime, which AAA accepted. Thereafter Caridaoan and Michelle managed the business while AAA, upon medical advice for heart disease, stayed home receiving PHP 4,000.00 monthly income and about PHP 5,000.00 for food and medicines, until her open-heart surgery on June 28, 2010 required three months' rest through September 2010, during which Caridaoan seldom came home. AAA's condition allegedly worsened with sleeplessness, crying, neglect of self, psychological consultation, a psychiatrist's diagnosis of severe panic disorder aggravated by psychological abuse, and a psychologist's finding of intense anxiety, inadequacy, weakness, low self-esteem, sadness, fatigue and crying spells rooted in emotional abuse and exclusion from the business. Helper Irene Aquino corroborated seeing AAA crying while Caridaoan and Michelle were together, their departure for Nueva Vizcaya, and the day-night arrangement.

For his part, Caridaoan testified that he met AAA in Ilocos Norte in 1998, lived with her a year later when he was a construction worker, and successively put up windshield repair and car wash businesses, the latter registered in AAA's name for a United States visa application. He described initial happiness followed by frequent quarrels over money and AAA's jealousy, including misinterpreting his remark about soft drinks being bad for Michelle during a Jollibee snack and angering him before customers, prompting him to tell AAA's father and then to end the relationship in the first week of February 2010. He claimed AAA initially refused but later accepted, even helping find a place, after which he courted Michelle and married her on March 22, 2010 in Nueva Vizcaya. He maintained AAA voluntarily entrusted the business permit for management, he provided money for medicines, gave all proceeds of their sold car to finance her operation without taking his share, seldom saw her thereafter, later discovered her boyfriend Sam, agreed to divide business proceeds, sold business properties to settle a barangay complaint, and was then charged though he never hurt her, as corroborated by BBB on AAA's calls to Sam.

The Information charged that from February 2010 toward the last quarter of 2010 Caridaoan willfully committed emotional and psychological abuse by purposely carrying an affair with Michelle inside their dwelling despite knowledge of AAA's heart condition, making Michelle co-manage the business, flaunting the relationship, and excluding AAA from its affairs and income, causing mental anguish, humiliation, depression, weakness, sadness, fatigue, crying spells, intense anxiety and withdrawal. The trial court credited AAA and found battered woman syndrome characterized by anxiety, inadequacy, weakness and insecurity, ruling that Caridaoan took advantage of her love through the dual arrangement and that alleged jealousy did not justify leaving her. The Court of Appeals sustained the factual finding of an eleven-year relationship, mental infidelity and resulting stress, but corrected the trial court that battered woman syndrome applies only as self-defense for crimes committed by a battered woman.

• Criminal Intent and Malice: Petitioner argued that ending a ten-year relationship with a person suffering rheumatic heart disease is not tantamount to psychological violence, there must be malice on the part of the accused, and anguish from a breakup is normal human experience.
• Timing of Affair and Separation: Petitioner maintained that the prosecution failed to prove an affair while still living with AAA, the records showing he formally ended the relationship before engaging with and marrying Michelle.
• Alleged Day-Night Arrangement: Petitioner argued that AAA's claim of an arrangement to live with Michelle in the morning and stay with AAA at night was incredible, categorically denied, never agreed to by his lawful spouse, and, even if assumed, voluntarily accepted by AAA.
• Psychological Evidence: Petitioner assailed the psychologist's findings as inaccurate for lack of verification through independent interviews or tests, arguing that low self-esteem, poor leadership or dependence does not establish abuse.

• Sufficiency of Prosecution Evidence: Respondent countered that AAA's categorical testimony proved emotional and psychological abuse through a relationship with Michelle while living with AAA, corroborated by psychological findings attributing anxiety and depression to the affair and deprivation of business share.
• Nature of Assigned Errors: Respondent argued that petitioner's contentions raised questions of fact improper in a petition for review on certiorari.

• Guilt for Psychological Violence: Whether Caridaoan is guilty of violating Section 5(i) of Republic Act No. 9262.

• Guilt for Psychological Violence: No. Acquittal was required on reasonable doubt, the prosecution having failed to prove willful infliction of mental anguish with criminal intent and direct causation under Section 5(i).

• Guilt for Psychological Violence: Section 5(i) punishes infliction of psychological violence, not the means per se, with a non-exclusive enumeration including repeated verbal and emotional abuse and denial of support, while Section 3(a) defines psychological violence to include marital infidelity among other acts; as a crime mala in se, conviction requires concurrence of actus reus and mens rea, namely intent to cause mental or emotional anguish, public ridicule or humiliation, plus separate proof of the anguish and a strong causal link. The third and fourth elements were not established because cohabitation and joint work did not prove a flaunted affair during the charged period, the evidence showing confession followed by departure and marriage rather than the charged conduct, and no exclusion from the business was shown where Michelle had been secretary since 2009, AAA admitted receiving food, medicines worth PHP 5,000.00 to PHP 6,000.00 monthly from March to August 2010, PHP 4,000.00 income share for September 30 to October 10, 2010, and proceeds of the co-owned vehicle for surgery, without proof of true business income, while absence from the shop coincided with doctor-ordered three-month rest after the June 2010 operation. Criminal intent was negated by continued support, hiring of helper Lanie, and AAA's admission that the arrangement was neither forced nor involuntary, compounded by Caridaoan's denial and AAA's material inconsistencies on when and what was arranged and admission of no intimacy during the alleged period. Causation likewise failed because the psychological report attributed distress to being left for another woman based solely on AAA's account, without considering who hired Michelle, how the living arrangement arose, how the affair was learned, or the financial support provided, which the examining psychologist admitted could materially affect assessment.

• Proof beyond reasonable doubt — Guilt must be proved to moral certainty sufficient to overcome presumed innocence and exclude every hypothesis except guilt; where inculpatory facts admit an explanation consistent with innocence, conviction cannot stand. Applied to acquit where the prosecution's own evidence supported absence of willful abuse.
• Nature of Section 5(i), Republic Act No. 9262 — What is punished is infliction of psychological violence causing mental or emotional anguish, public ridicule or humiliation, not the particular means employed, the statutory examples being non-exclusive by the phrase but not limited to. Applied to focus inquiry on willful causation rather than mere occurrence of infidelity or business management.
• Psychological violence; marital infidelity — Section 3(a) defines psychological violence as acts or omissions causing or likely to cause mental or emotional suffering such as but not limited to intimidation, harassment, stalking, damage to property, public ridicule or humiliation, repeated verbal abuse, and marital infidelity. Applied as interpretive backdrop for Section 5(i) without dispensing with intent and causation.
• Section 5(i) as mala in se; mens rea — Crimes under Section 5(i) and 5(e) of Republic Act No. 9262 are mala in se requiring concurrence of actus reus and mens rea, the latter being the causing of mental or emotional anguish, public ridicule or humiliation; good faith and lack of criminal intent are defenses. Applied to require deliberate purpose to inflict anguish, following Acharon vs. People, and to acquit where support and good faith were shown.
• Elements of violation of Section 5(i) — The prosecution must prove (1) the offended party is a woman and/or her child; (2) the woman is the wife, former wife, or one with whom the offender has or had a sexual or dating relationship or common child; (3) the offender causes mental or emotional anguish; and (4) the anguish is caused through public ridicule or humiliation, repeated verbal and emotional abuse, denial of support or custody or access, or similar acts or omissions. Applied to find reasonable doubt on the third and fourth elements.
• Distinction between violent act and effect; causation — The psychological violence committed and the damage sustained must be separately proved, the latter through the woman's personal testimony, with proof that anguish resulted from or was directly attributable to acts intentionally committed to inflict emotional violence. Applied to reject liability for distress inherent in relationship breakup absent strong causation.

• "In our criminal justice system, the overriding consideration is not whether the court doubts the innocence of the accused but whether it entertains reasonable doubt as to his guilt." — States the governing standard of proof requiring acquittal where moral certainty of guilt is lacking.
• "From the plain language of the afore-quoted provision, what the law punishes is the infliction of psychological violence on the woman or her child and not the means employed by the accused to perpetrate the crime." — Defines the gravamen of Section 5(i) and frames the need to prove willful infliction rather than mere infidelity.
• "Truly, ending a relationship is heartbreaking and causes one to experience, among others, emotional distress, anxiety, and depression. However, that the woman experiences mental or emotional distress in a relationship does not automatically translate to a crime of psychological violence and criminal liability under Republic Act No. 9262." — Distinguishes ordinary breakup anguish from criminal psychological violence requiring deliberate causation.

• Acharon vs. People, 913 Phil. 731 (2021) — En Banc ruling that Section 5(i) and 5(e) are mala in se requiring mens rea; followed as controlling basis for requiring criminal intent and for acquittal.
• XXX261920 vs. People, 938 Phil. 619 (2023) — Applied to extend Acharon beyond denial of support to other Section 5(i) predicates and to require indubitable nexus between the charged act and anguish; followed to acquit for absence of guilty mind and causation.
• Dinamling vs. People, 761 Phil. 356 (2015) — Cited for the proposition that Section 5(i) punishes infliction of psychological violence rather than the means; followed in construing the provision.
• People vs. Genosa, 464 Phil. 680 (2004) — Relied upon by the RTC for battered woman syndrome; the Court of Appeals held its application erroneous because the syndrome applies as self-defense for crimes committed by a battered woman.
• Calingasan vs. People, 919 Phil. 943 (2022); XXX vs. People, 949 Phil. 321 (2023); XXX vs. People, 939 Phil. 446 (2023) — Cited as applications of Acharon acquitting for failure to prove deliberate refusal of support motivated by ill will; used to reinforce the intent requirement.

• Section 5(i), Republic Act No. 9262 — Punishes causing mental or emotional anguish, public ridicule or humiliation to the woman or her child, including but not limited to repeated verbal and emotional abuse and denial of financial support or custody or access; applied as the offense charged, with its non-exclusive means requiring proof of willful causation.
• Section 3(a), Republic Act No. 9262 — Defines psychological violence as acts or omissions causing or likely to cause mental or emotional suffering such as but not limited to intimidation, harassment, stalking, damage to property, public ridicule or humiliation, repeated verbal abuse, and marital infidelity; applied to interpret the acts cognizable under Section 5(i).

Associate Justices Inting, Dimaampao and Marquez concurred. Associate Justice Singh was on leave.