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AAA v. PEOPLE

FACTS:

AAA, the petitioner, filed a petition for review on certiorari seeking the reversal of the decision of the Court of Appeals (CA) affirming the guilty verdict of the Regional Trial Court (RTC) in a case involving a violation of the Anti-Violence Against Women and Their Children Act of 2004. The information filed against the petitioner alleged that he committed acts of violence against his wife, BBB, by taking their conjugal properties and bringing them to his mother's house without her consent. The prosecution presented two witnesses, BBB and CCC, who testified that the petitioner physically harmed and verbally abused BBB during an argument about her supposed indebtedness. The petitioner claimed that he only wanted to protect their properties from being confiscated by debt collectors and that he did not intend to inflict emotional pain on BBB. The RTC found the petitioner guilty, and the CA affirmed the decision with a modification in the penalty imposed. The petitioner argues that his actions do not constitute emotional and psychological abuse under the law and that the evidence presented does not overcome his presumption of innocence. The Solicitor General, in its comment, argued that the testimony of BBB established mental and emotional anguish caused by the petitioner's actions.

ISSUES:

  1. Whether or not the petitioner violated Sec. 5(i) of R.A. No. 9262.

  2. Whether or not the petitioner caused mental or emotional anguish to the woman and/or her child.

  3. Whether the mitigating circumstance of passion and obfuscation should be applied.

  4. Whether the additional penalties of fine and mandatory psychological counseling or treatment should be imposed.

RULING:

  1. The Court ruled that the petitioner violated Sec. 5(i) of R.A. No. 9262. The elements required for conviction were present in the case.

  2. The Court found that the petitioner caused mental and emotional anguish to the woman based on her testimony and the evidence presented. The anguish was caused through acts of public ridicule or humiliation, repeated verbal and emotional abuse, denial of financial support or custody of minor children, and denial of access to the woman's child/children.

  3. The mitigating circumstance of passion and obfuscation should not be applied to mitigate the penalty imposed on the petitioner. The elements for the consideration of this circumstance are missing, as there was no unlawful act committed against the petitioner by the private complainant that would cause such a reaction from him. The private complainant's acts also do not provide a legitimate stimulus justifying the petitioner's loss of reason and self-control.

  4. The lower courts erred in failing to impose the additional penalties of fine and mandatory psychological counseling or treatment on the petitioner. Section 6 of R.A. No. 9262 provides that in addition to imprisonment, the perpetrator of violence against women and their children shall pay a fine and undergo mandatory psychological counseling or psychiatric treatment. Thus, the petitioner is ordered to pay a fine of One Hundred Thousand Pesos (P100,000.00) and undergo mandatory psychological counseling or psychiatric treatment.

PRINCIPLES:

  • Psychological violence, defined as acts or omissions causing or likely to cause mental or emotional suffering to the victim, is penalized under Sec. 5(i) of R.A. No. 9262.

  • To establish the element of mental or emotional anguish, the testimony of the victim must be presented, as these experiences are personal to the party.

  • The determination of mental or emotional anguish is based on the effect caused upon or the damage sustained by the offended party.

  • Proof beyond reasonable doubt is required to overcome the presumption of innocence and secure conviction in a criminal case.

  • In criminal cases, an appeal throws the entire case wide open for review and allows the reviewing tribunal to correct errors, though unassigned, in the appealed judgment. It confers the appellate court full jurisdiction over the case.

  • Modifying circumstances may be appreciated to determine the periods of the corresponding penalties or to reduce the penalty by degrees in offenses defined and punished under a special law, when the penalty is actually taken from the Revised Penal Code.

  • The mitigating circumstance of passion and obfuscation requires the presence of an unlawful act sufficient to produce such condition of mind and that the act which produced the obfuscation was not far removed from the commission of the crime by a considerable length of time, during which the perpetrator might recover his moral equanimity.

  • The additional penalties of fine and mandatory psychological counseling or treatment are imposed in addition to imprisonment for the crime of violence against women and their children.