GR 252739 Singh (Digest)
G.R. No. 252739, April 16, 2024
XXX, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner XXX was charged with violating Section 5(i) of Republic Act No. 9262 (the Violence Against Women and Their Children Act) for keeping a mistress, which caused his wife, AAA, mental and emotional anguish. The Regional Trial Court convicted XXX, finding the emotional anguish of his wife apparent during her testimony. The Court of Appeals affirmed the conviction, holding that the element of causing mental or emotional anguish was sufficiently proven. The ponencia (main decision by Justice Hernando) affirmed the conviction, concluding that marital infidelity resulting in mental and emotional anguish is punishable under the law. This Separate Concurring Opinion by Justice Singh agrees with the ponencia’s affirmation of conviction but elaborates on the legal reasoning.
ISSUE
Whether, for a conviction under Section 5(i) of R.A. No. 9262 for psychological violence through marital infidelity, the prosecution must prove the accused’s specific intent to cause mental or emotional anguish upon the victim.
RULING
No. The specific intent to cause mental or emotional anguish need not be proved to convict an accused for inflicting psychological violence through marital infidelity. The pronouncement in Acharon v. People—requiring proof of such intent—should be limited in application to the act of willful denial of financial support. For psychological violence committed through marital infidelity, the specific intent to cause mental or emotional anguish is presumed. Marital infidelity is a deliberate breach of trust and a conscious choice to engage in actions that violate marital vows. The emotional distress suffered by the victim-spouse is a natural, logical, and foreseeable consequence of the infidelity itself. The act of infidelity inherently demonstrates a disregard for the spouse’s emotional well-being. Therefore, when the prosecution proves the act of marital infidelity and the resulting mental or emotional anguish, the law presumes the requisite criminal intent. The law must be liberally construed to promote the protection of victims. Consequently, the petitioner’s conviction is affirmed.