GR 212448; (January, 2018) (Digest)
G.R. No. 212448 , January 11, 2018
AAA, Petitioner, vs. BBB, Respondent.
FACTS
Petitioner AAA and respondent BBB were married in Quezon City. BBB worked as a chef in Singapore, acquiring permanent resident status. AAA, a flight attendant, resided with their children in Pasig City. AAA alleged BBB provided little financial support and committed various abuses. The central allegation was that BBB caused her mental and emotional anguish by maintaining an illicit relationship with another woman in Singapore. This culminated in a violent altercation in a Singapore hotel on April 19, 2011.
An Information was filed under Section 5(i) of R.A. No. 9262 (Anti-Violence Against Women and Their Children Act) charging BBB with psychological violence through marital infidelity. The Regional Trial Court (RTC) of Pasig granted BBB’s motion to quash the Information, dismissing the case for lack of jurisdiction. The RTC ruled that the criminal act—the alleged illicit relationship—occurred in Singapore, outside its territorial jurisdiction, and that the resulting anguish felt by AAA in the Philippines was insufficient to confer jurisdiction.
ISSUE
Whether Philippine courts can exercise jurisdiction over a violation of R.A. No. 9262 , where the alleged psychological violence through marital infidelity was committed abroad.
RULING
Yes. The Supreme Court granted the petition and reinstated the Information. The Court clarified that for crimes under R.A. No. 9262 , jurisdiction is determined by the venue of the offense, not by the place where the acts causing the violence were committed. Section 7 of the law provides that criminal actions may be filed in the regional trial court where the crime or any of its elements was committed, or where the offended party resides at the time of the commission of the offense. Psychological violence is a continuing crime; the mental or emotional anguish it produces is not a single, instantaneous event confined to a specific location. The anguish is felt and suffered by the victim in her place of residence. Since AAA was a resident of Pasig City, the RTC of Pasig correctly acquired jurisdiction over the case. The ruling emphasizes the protective intent of R.A. No. 9262 , ensuring that offenses with transnational elements do not evade Philippine judicial reach simply because the perpetrator’s acts occurred overseas, so long as the victim is a resident within the Philippines.