G.R. No. 247429 , September 08, 2020
Jaime Araza y Jarupay, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner Jaime Araza was charged with violating Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act) for psychological violence against his wife, AAA. The Information alleged that from September 2007, Araza willfully committed psychological abuse through marital infidelity, cohabiting with Tessie Luy Fabillar and siring three children, causing AAA emotional anguish. AAA testified that after discovering the affair in 2007, an amicable settlement was reached, but Araza soon abandoned her to return to his mistress. This caused AAA severe depression, requiring medication, and led her to spend considerable resources searching for him and filing legal actions, including a dismissed habeas corpus petition. The prosecution presented a friend who corroborated seeing Araza with his paramour and a psychiatrist who diagnosed AAA’s depressive symptoms as secondary to the relational distress caused by Araza’s infidelity and abandonment.
Araza denied the allegations, claiming he left due to AAA’s own infidelity and that their separation was mutual. He asserted he was merely a boarder in Fabillar’s house and that the children were not his. The Regional Trial Court found him guilty, a decision affirmed by the Court of Appeals. The CA held that the prosecution successfully established psychological violence through Araza’s acts of infidelity, cohabitation, and siring illegitimate children, which caused mental and emotional suffering to AAA.

ISSUE

Whether the Court of Appeals erred in affirming Araza’s conviction for psychological violence under R.A. No. 9262 .

RULING

The Supreme Court denied the petition and affirmed the conviction. The legal logic centered on the elements of psychological violence under Section 5(i) of R.A. No. 9262 . The Court clarified that psychological violence is an act causing mental or emotional suffering, and marital infidelity can constitute such an act. The prosecution proved beyond reasonable doubt that Araza committed infidelity by cohabiting with another woman and having children with her. His actions were not isolated but formed a pattern of behavior that directly caused AAA’s documented psychological harm, including depression and anxiety, as confirmed by expert testimony.
The Court rejected Araza’s defenses as unsubstantiated and contrary to human experience. His claim of being a mere boarder was belied by the birth of three children from the affair. His allegation of AAA’s infidelity was a bare assertion without proof. The totality of evidence—AAA’s credible testimony, the corroborating witness, and the psychiatric evaluation—conclusively established that Araza’s acts were calculated to cause mental suffering, thereby constituting psychological violence. The penalty imposed by the lower courts was within the range provided by law, considering the absence of modifying circumstances.