XXX270257 vs. People of the Philippines

The elements of psychological violence under Section 5(i) of RA 9262 are: (1) the offended party is a woman and/or her child; (2) the woman is the wife, former wife, or has a sexual/dating relationship with the offender; (3) the offender causes mental or emotional anguish; and (4) the anguish is caused through acts like public ridicule, repeated verbal abuse, denial of financial support, or similar acts. The victim's testimony in court is sufficient to prove emotional anguish; a psychological evaluation is not required.

The case involves a prosecution under Republic Act No. 9262, which criminalizes violence against women and their children. The specific charge was for psychological violence under Section 5(i), which penalizes causing mental or emotional anguish through acts such as denial of financial support, repeated verbal and emotional abuse, or public ridicule.

• Filed in the Regional Trial Court (RTC) of La Trinidad, Benguet (Criminal Case No. 18-CR-12464).
• The RTC found the petitioner guilty beyond reasonable doubt in a Judgment dated July 3, 2020.
• The petitioner appealed to the Court of Appeals (CA).
• The CA affirmed the RTC judgment in toto in a Decision dated February 8, 2023, and denied reconsideration in a Resolution dated September 6, 2023.
• The petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari.

• The petitioner (XXX270257) and private complainant (AAA) were married in 1998 and had three children.
• On January 1, 2017, the petitioner left the conjugal home. AAA later discovered he was living with another woman, CCC.
• The petitioner cohabited with CCC in his mother's house, which was adjacent to the conjugal home, making the affair visible to AAA and their children.
• The petitioner and CCC had a child together, which he acknowledged.
• The petitioner failed to provide adequate financial support to his children with AAA.
• AAA testified that these acts caused her mental and emotional anguish, including depression, anxiety, and sleep difficulties.

• A psychological evaluation or assessment by an expert is indispensable to prove psychological violence under RA 9262.
• The prosecution failed to properly present the psychologist as a witness or stipulate on the psychological report, violating his right to due process.
• The psychological evaluation was conducted 22 months before pre-trial, making its late admission prejudicial.

• The prosecution's evidence, primarily AAA's testimony, sufficiently proved all elements of the crime.
• The petitioner's acts of marital infidelity, abandonment, and flaunting the relationship caused AAA emotional anguish.
• The petitioner's defense of denial is weak and cannot overcome the positive and credible testimony of the victim.

• Procedural Issues: Whether the late presentation of the psychological report and the psychologist as a witness violated the petitioner's right to due process.
• Substantive Issues: Whether the CA erred in finding the petitioner guilty of violating Section 5(i) of RA 9262.

• Procedural: The SC did not squarely address the procedural due process argument, as it found the substantive issue dispositive. It implicitly rejected the need for the psychological report by ruling it is not indispensable.
• Substantive: The SC affirmed the conviction. It held that all elements of psychological violence under Section 5(i) of RA 9262 were proven. The victim's testimony alone was sufficient to establish emotional anguish. The petitioner's acts of abandonment, cohabiting with another woman adjacent to the family home, siring an illegitimate child, and failing to provide adequate support constituted the prohibited acts.

• Elements of Psychological Violence under Section 5(i) of RA 9262 — As derived in Dinamling v. People, the four elements are: (1) the offended party is a woman/child; (2) the woman is the wife/former wife or has a relationship with the offender; (3) the offender causes mental/emotional anguish; (4) the anguish is caused through acts like public ridicule, denial of support, etc.
• Proof of Emotional Anguish — As held in Araza v. People and Labrador v. People, the testimony of the victim in court is sufficient to prove emotional anguish; a psychological evaluation or expert testimony is not an indispensable element of the crime.

• "Psychological violence is the means employed by the perpetrator, while emotional anguish or mental suffering are the effects caused to or the damage sustained by the offended party. 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." — Citing Araza v. People.
• "It is settled that the positive and categorical testimony of the victim prevails over the bare denial of the accused." — On the weakness of the petitioner's defense.

• Dinamling v. People — Cited to establish the four elements of a violation of Section 5(i) of RA 9262.
• Labrador v. People — Cited to support the ruling that a psychological evaluation is not indispensable to prove psychological violence.
• Araza v. People — Cited for the doctrine that the victim's testimony suffices to prove emotional anguish and for the standard penalty and damages in RA 9262 cases.
• XXX v. People (893 Phil. 840) — Cited for the principle that the victim's positive testimony prevails over the accused's denial.

• Section 5(i) of Republic Act No. 9262 — Defines and penalizes acts of psychological violence against women and their children, specifically causing mental or emotional anguish through acts like denial of financial support, repeated verbal abuse, or public ridicule.
• Section 6 of Republic Act No. 9262 — Provides the penalty for violations, which is prision mayor, a fine, and mandatory psychological counseling.
• Section 36 of Republic Act No. 9262 — Entitles the victim to moral damages.

• Caguioa, J. (Concurring) — Emphasized that crimes under Section 5(i) are mala in se, requiring both actus reus (the prohibited acts) and mens rea (the specific intent to cause anguish). He distinguished this case from XXX v. People, arguing that here, the petitioner's acts of flaunting his infidelity in full view of his family and on social media demonstrated the requisite intent to inflict psychological violence.