G.R. No. 255466, November 27, 2024
BBB255466, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner BBB255466 and his live-in partner, CCC, began their relationship in 2003 and have a child, AAA. CCC testified that she suffered repeated physical and verbal abuse from BBB255466 throughout their relationship. Specific acts included throwing a liquefied petroleum gas tank at her, chasing her with a bolo while threatening to chop her into pieces, forcibly gaining access to her boarding house after she left him, forcibly taking custody of AAA, constantly demanding money, and making verbal threats when she refused to reconcile. BBB255466 was charged and convicted under Section 5(i) of Republic Act No. 9262 (Psychological Violence) for causing mental or emotional anguish through repeated verbal and emotional abuse, and under Article 336 of the Revised Penal Code in relation to RA 7610 for Acts of Lasciviousness. Notably, the acts alleged involved physical and verbal abuse which could also fall under other provisions of RA 9262 (e.g., Section 5(a) for causing physical harm, or Section 5(b) for threats of physical harm), but the charge was specifically under Section 5(i).

ISSUE

Whether the conviction under Section 5(i) of RA 9262 is proper, given that the acts complained of involved physical and verbal abuse, and what is the required criminal intent for a violation of Section 5(i).

RULING

The conviction under Section 5(i) of RA 9262 is affirmed. The crime under Section 5(i) is mala in se; it requires proof that the accused willfully or intentionally caused mental or emotional anguish, public ridicule, or humiliation to the woman or her child. It is not enough that the victim experienced mental or emotional anguish. The prosecution must prove that the accused consciously committed the acts for the purpose of inflicting such mental and emotional anguish. In this case, CCC’s clear testimony established that BBB255466’s repeated physical and verbal abuse throughout their relationship, and even after separation, were specifically intended to cause her mental and emotional suffering. His actions created a cycle of fear, keeping CCC in a constant state of anxiety and hyper-vigilance for herself and their daughter. Therefore, the prosecution proved beyond reasonable doubt the specific criminal intent required under Section 5(i). The Concurring Opinion emphasizes this framework for determining intent when acts involve physical and verbal abuse, and concurs in denying the Petition for Review on Certiorari.