The Supreme Court (SC) reiterated that a psychological evaluation is not required to prove psychological violence under Republic Act No. 9262 or the Anti-Violence Against Women and Their Children (VAWC) Act.

In a Decision penned by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division affirmed the conviction of XXX270257 (accused) for psychological violence against his wife and children.

The case stemmed from the accused’s extramarital affair, abandonment of his family, and failure to provide financial support to his children. 

The lower courts found that all elements of psychological violence under Section 5 (i) of the Anti-VAWC Act were present: (1) the victim is a woman and/or her child; (2) the victim is the wife or has a relationship with the offender; (3) the offender causes the victim mental or emotional anguish; and (4) the anguish is caused through public humiliation, verbal and emotional abuse, denial of financial support, or similar acts.

The accused argued that to prove the element of mental or emotional anguish, the prosecution must show a psychological report to establish psychological violence.

The SC clarified that a psychological evaluation from an expert witness is not necessary to prove psychological violence; the victim’s testimony is sufficient to prove emotional or mental suffering.

His wife’s detailed testimony in court proved her mental and emotional anguish. She recounted how he left their home to live with another woman right next door, fathered a child with her, and flaunted his affair on social media. 

The accused was sentenced to up to eight years in prison, fined PHP 200,000, and ordered to pay PHP 75,000 in damages. The SC also directed him to undergo psychological counseling or psychiatric treatment.  (Courtesy of the SC Office of the Spokesperson)

This press release is prepared for members of the media and the general public by the Supreme Court Office of the Spokesperson as a simplified summary of the SC’s Decision. For the SC’s complete discussion of the case, please read the full text of the Decision in G.R. No. 270257 (XXX270257 v. People and AAA, August 12, 2024) at:  https://sc.judiciary.gov.ph/270257-xxx270257-vs-people-of-the-philippines-and-aaa