G.R. No. 229762 , November 28, 2018
AAA, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner AAA was charged with violating Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act). The information alleged that on February 17, 2010, he willfully committed acts of violence against his wife, BBB, by taking their conjugal properties to his mother’s house without regard to her feelings and against her will, causing her mental and emotional anguish. The prosecution established that during a heated argument concerning BBB’s undisclosed debts, for which household appliances were collateral, petitioner forcibly took items including a television, refrigerator, and bed. BBB testified that she tried to stop him, resulting in her being “mauled.” Their daughter witnessed the argument and the removal of the items.
The defense presented petitioner as its sole witness. He claimed he moved the properties to safeguard them from imminent confiscation by creditors due to his wife’s debts, which were incurred without his knowledge. He admitted pushing his wife aside when she blocked the door but denied any intent to cause emotional harm, asserting he acted to protect the fruits of his labor. Both the Regional Trial Court and the Court of Appeals found him guilty, with the CA applying the mitigating circumstance of passion and obfuscation to reduce his penalty.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that petitioner’s acts constituted emotional and psychological abuse under R.A. No. 9262 , thereby overcoming the constitutional presumption of innocence.

RULING

The Supreme Court denied the petition and affirmed the CA’s modified decision. The Court held that all elements of the crime under Section 5(i) of R.A. No. 9262 were established. First, the parties were legally married. Second, petitioner’s act of taking the household properties over his wife’s objection and his accompanying physical act of pushing her constituted “psychological violence” and “emotional abuse” as defined by the law. The law defines such abuse as acts or omissions causing mental or emotional suffering, such as public ridicule, repeated verbal abuse, and marital infidelity. The act of dispossessing the wife of the family’s household items, which are integral to domestic life, against her will and in a manner that involved physical confrontation, naturally resulted in mental anguish, fear, and emotional distress.
The Court rejected petitioner’s argument that his intent was merely to protect the property. The law penalizes the abusive act and its effect, not the specific intent to cause emotional anguish. His claim of a lawful purpose did not negate the unlawful means employed and the proven consequence of psychological harm to the victim. The trial courts’ factual findings on the credibility of the victim’s testimony regarding the anguish suffered were accorded finality. The mitigating circumstance of passion and obfuscation, correctly applied by the CA, did not exonerate him but merely warranted a penalty reduction, as his emotional reaction, while understandable, did not justify the commission of the punishable act. Thus, his guilt was proven beyond reasonable doubt.