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AAA v. BBB

FACTS:

AAA and BBB were married and had two children. BBB allegedly had an affair with a Singaporean woman named Lisel Mok, causing AAA mental and emotional anguish. AAA filed a case against BBB for violating R.A. No. 9262. A warrant of arrest was issued against BBB, but he evaded it. BBB's counsel filed a motion to quash the information, arguing lack of jurisdiction. The trial court granted the motion and dismissed the case.

AAA filed a petition with the Supreme Court, arguing that the trial court's ruling allows husbands of Filipino women to engage in extramarital affairs abroad without consequence. BBB claims that the grant of the motion to quash is equivalent to an acquittal. The Supreme Court determines that the petition was timely filed and clarifies that the grant of the motion to quash does not amount to an acquittal.

In a separate case, petitioners filed a complaint against private respondents for damages, alleging abuse of rights and breach of contract. The RTC dismissed the complaint for lack of jurisdiction, as it involved a boundary dispute between barangays. The Court of Appeals affirmed the dismissal, ruling that the RTC did not commit grave abuse of discretion. The petitioners filed a petition for review on certiorari.

ISSUES:

  1. May Philippine courts exercise jurisdiction over an offense constituting psychological violence under Republic Act No. 9262 committed through marital infidelity, when the illicit relationship occurred outside the country?

RULING:

  1. Yes, Philippine courts may exercise jurisdiction over the offense of psychological violence under Republic Act No. 9262 committed through marital infidelity, even if the illicit relationship occurred outside the country. The resulting mental or emotional anguish experienced by the complainant within the territorial jurisdiction of the court is crucial. Since the wife and children are residents of Pasig City, the RTC of Pasig City may exercise jurisdiction over the case.

PRINCIPLES:

  1. Transitory or Continuing Crimes: Acts of violence that may occur in different territorial jurisdictions can be considered as transitory or continuing offenses, thus can be tried where any element of the crime occurred.

  2. Territorial Jurisdiction in Criminal Cases: For jurisdiction to be acquired in criminal cases, some acts material and essential to the crime must occur within the territorial jurisdiction of the court.

  3. Psychological Violence Under RA 9262: Marital infidelity alone is not criminalized, but the resulting psychological violence causing mental or emotional suffering is.

  4. Filing Venue Under RA 9262: According to Sec. 7 of RA 9262, cases may be filed in the Regional Trial Court where the crime or any of its elements was committed, at the option of the complainant.