Battered Woman Syndrome (BWS) refers to a scientifically defined pattern of psychological and behavioral symptoms found in women living in battering relationships as a result of cumulative abuse (Section 3(d), Republic Act No. 9262; People v. Genosa). This syndrome is characterized by a cycle of violence comprising three phases: the tension-building phase, the acute battering incident, and the tranquil, loving (or at least, non-violent) phase (People v. Genosa). For a woman to be classified as battered, this cycle must have occurred at least twice. Under Section 26 of Republic Act No. 9262, victim-survivors found by the courts to be suffering from BWS do not incur criminal and civil liability, notwithstanding the absence of any of the elements for justifying circumstances of self-defense under the Revised Penal Code. While the law seemingly dispenses with the element of unlawful aggression, the Supreme Court in People v. Genosa clarified that unlawful aggression, or at least its imminence, remains crucial to the BWS defense, requiring the battered woman to have actually feared imminent harm from her batterer and honestly believed in the need to kill him to save her life. Expert witness testimony is essential to properly understand and prove the syndrome. If not considered a justifying circumstance, BWS may still be appreciated as a mitigating circumstance, such as passion and obfuscation or an illness that diminishes will power, due to the cumulative provocation and psychological paralysis caused by the cyclical violence (People v. Genosa).