G.R. No. 243049 , October 05, 2020
XXX, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner XXX was charged with violating Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act) for causing mental or emotional anguish to his wife, AAA. The prosecution established that after 17 years of marriage, AAA discovered XXX’s extramarital affair, which he initially denied. This led to a heated argument, resulting in XXX leaving their conjugal home in February 2013. Subsequently, on June 6, 2013, AAA received a threatening text message from XXX stating, in essence, that his life was ruined and he could not control what he might do to her and their children. Fearing for their safety, AAA reported the incident and secured a permanent protection order.
The defense presented XXX as its sole witness. He denied the affair, attributing the marital strife to unfounded rumors, and claimed he was forced to leave their home. He also presented an Affidavit of Desistance executed by AAA, who purportedly wished to discontinue the case due to their daughter’s nervous breakdown. However, during cross-examination, XXX admitted to having committed past acts of infidelity.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of XXX for violation of Section 5(i) of RA 9262.

RULING

The Supreme Court denied the petition and affirmed the conviction with modification. The legal logic centered on the sufficiency of evidence proving psychological violence. The Court held that the element of causing mental or emotional anguish was conclusively established through AAA’s credible testimony regarding the discovery of the affair, the subsequent separation, and the receipt of the threatening text message, which induced fear. Crucially, XXX’s own judicial admission during cross-examination—that he had committed acts of infidelity—buttressed the finding that his conduct caused the requisite psychological abuse. A judicial admission is binding and cannot be contradicted.
The Court found no reason to disturb the consistent factual findings of the lower courts, which are accorded great weight on appeal, especially concerning witness credibility. However, the penalty was modified. The Court noted that under Section 6(f) of RA 9262, the penalty for violations of Section 5(i) includes, in addition to imprisonment and a fine, mandatory psychological counseling or psychiatric treatment. Both the RTC and CA omitted this mandatory component. Thus, the Supreme Court imposed the indeterminate penalty of six months and one day of prision correccional, as minimum, to six years and one day of prision mayor, as maximum, a fine of P100,000.00, and the requirement for XXX to undergo mandatory psychological counseling or psychiatric treatment and report his compliance to the court.