G.R. No. 256759 , November 13, 2023
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 allegedly inflicting psychological violence on his wife, AAA. The prosecution alleged that from June 2014 onward, petitioner persuaded AAA to secure a loan of PHP 1,000,000.00 under the pretext of purchasing a van for a family business and augmenting their children’s tuition fees. AAA issued checks and allowed ATM withdrawals totaling significant amounts, which petitioner received. However, petitioner failed to purchase the van, did not fully pay the tuition fees, and could not account for the money. AAA’s subsequent demands for accountability were met with refusal and avoidance. This series of events allegedly caused AAA mental and emotional anguish, manifesting in physical illness and an inability to focus at work, which was corroborated by her children and mental health professionals.
For his defense, petitioner denied the allegations, claiming it was AAA’s idea to secure the loan for tuition and that the money he received was used for a joint microlending business. He asserted he provided regular family support, purchased items for the children, and only sometimes delayed tuition payments due to lack of funds. He admitted the business later failed as borrowers defaulted. The Regional Trial Court convicted petitioner, a ruling affirmed by the Court of Appeals, prompting this petition.

ISSUE

Whether the Court of Appeals erred in affirming petitioner’s conviction for psychological violence under Section 5(i) of RA 9262.

RULING

The Supreme Court denied the petition and affirmed the conviction. The legal logic centered on the elements of psychological violence under RA 9262: (1) the offended party is a woman and/or her child; (2) the woman or child has suffered mental or emotional anguish; and (3) the anguish is caused by acts of the accused. The Court found all elements present. AAA, as the legal wife, is a protected party under the law. The element of mental anguish was conclusively established not only by AAA’s credible testimony detailing her distress, pneumonia, and work difficulties but also by the corroborative testimonies of her children and the expert findings of a psychiatrist and a psychologist.
Crucially, the Court ruled that this anguish was directly caused by petitioner’s acts, which constituted psychological violence. His act of procuring a substantial loan from his wife through false pretenses regarding its use for family welfare, followed by his failure to account for the funds and his subsequent refusal to communicate or properly address her legitimate concerns, was deemed a form of psychological abuse. The law encompasses acts that undermine a woman’s psychological integrity, and petitioner’s pattern of deception and financial manipulation, which exploited the marital trust and caused severe anxiety over family finances and children’s welfare, squarely fell within this prohibition. His defenses of providing sporadic support and blaming a failed business were insufficient to overturn the consistent factual findings of the lower courts, which affirmed the presence of psychological violence beyond reasonable doubt.