G.R. No. 252739, April 16, 2024
XXX, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

The petitioner, XXX, was charged with and found guilty of violating Section 5(i) of Republic Act No. 9262 (The Anti-Violence Against Women and Their Children Act of 2004). The specific act involved causing mental or emotional anguish. The concurring opinion of Justice Lopez agrees with the ponencia’s finding of guilt beyond reasonable doubt but seeks to elaborate on why specific intent to cause mental or emotional anguish need not be proven for a conviction under the said law.

ISSUE

Whether specific intent to cause mental or emotional anguish or psychological suffering on the victim is a necessary element that must be proven for a conviction under Section 5(i) of Republic Act No. 9262.

RULING

No. Specific intent to cause mental or emotional anguish is not a required element. The concurring opinion elucidates that for psychological violence under R.A. No. 9262, the perspective of the offended party, not the intent of the offender, is of primary significance. The law, as defined in Section 3(c), covers acts or omissions “causing or likely to cause mental or emotional suffering,” with marital infidelity cited as an example. The legislative intent, as revealed in the deliberations, was to address historical and structural inequalities against women, recognizing that societal norms have condoned male marital infidelity and created a power imbalance. The law aims to protect women and children from the effects of such acts, regardless of the perpetrator’s specific intent to cause psychological harm. The focus is on the resultant mental or emotional suffering caused to the victim.