Dabalos v. RTC, G.R. No.

193960, January 7, 2013

Facts
Karlo Angelo Dabalos was charged with violation of Section 5(a) of R.A. 9262 for inflicting physical
injuries on his former girlfriend (ABC). The Information alleged that on July 13, 2009, Dabalos pulled her
hair, and punched her on her back, shoulder, and left eye, thereby degrading her dignity. Dabalos filed a
Motion for Judicial Determination of Probable Cause with Motion to Quash, arguing that they were no
longer in a dating relationship at the time of the incident, and thus, the case should not fall under R.A.
9262. ABC confirmed in her affidavit that their relationship had already ended before the incident but
explained the altercation arose when she confronted him about unpaid debts and rumors he had spread.
The RTC denied the motion, holding that the prior existence of a dating relationship was enough for R.A.
9262 to apply.

Issue
Whether R.A. 9262 still applies if the act of violence occurred after the dating relationship had already
ended.

Ruling: Yes.
The Supreme Court dismissed the petition. It ruled that the existence of a past dating relationship
satisfies one of the elements under R.A. 9262, and the law does not require that the act of violence be a
result of or occur during the relationship. It is sufficient that violence was committed by a person with
whom the victim had a dating relationship, regardless of whether the relationship was ongoing at the
time of the offense.

Doctrine
For an act to fall under the coverage of R.A. 9262:
1. The offender must have or had a dating or sexual relationship with the woman (or be her
husband or have a common child with her); and
2. The act must result in physical, sexual, psychological harm or suffering, or economic abuse.
The continuity or timing of the relationship with respect to the act of violence is not controlling. The law
does not distinguish between current and former relationships—thus, courts should not distinguish
either.
Additionally, a higher penalty under R.A. 9262 is justified to protect women from persons with whom
they had intimate relationships, even if the relationship has already ended.

Even if Slight Physical injury is present, the case still falls under VAWC even if the dating relationship had
already ended. (ubi lex non nec nos distinguire debemos - applying the rule on statutory construction
that when the law does not distinguish, neither should the courts, then, clearly, the punishable acts refer
to all acts of violence against women with whom the offender has or had a sexual or dating relationship)
Araza v. People, G.R. No. 247429, September 08, 2020

Facts:
Jaime Araza was convicted of violating Section 5(i) of R.A. No. 9262 for causing psychological abuse to
his wife, AAA, through marital infidelity. He cohabited with his mistress, Tessie Fabillar, and fathered
three children with her, causing AAA emotional anguish.
AAA testified about her husband's betrayal, her efforts to locate him, and her resulting mental distress. A
psychologist confirmed that her symptoms—like depression and insomnia—were due to relational
distress.
Araza denied the affair, but the courts gave more weight to AAA’s testimony and medical findings. Both
the RTC and CA held that it was not the affair itself that was punishable, but the emotional suffering it
caused, thus affirming Araza’s conviction.

Issue:
Whether or not the petitioner, Jaime Araza, is guilty of psychological violence under Section 5(i) of RA
9262.

Ruling:
Yes, the Supreme Court affirmed the conviction of Jaime Araza. The Court held that the repeated
infliction of emotional and psychological abuse on his partner constituted a clear violation of Section 5(i)
of RA 9262. The victim’s testimony, corroborated by the surrounding circumstances, was sufficient to
prove psychological violence.
The Court emphasized that such abuse can take the form of verbal and emotional abuse, public
humiliation, and other acts causing mental or emotional suffering — even in the absence of physical
violence.

Doctrine:
Under Section 5(i) of RA 9262, psychological violence refers to acts or omissions causing or likely to
cause mental or emotional suffering of the woman or her child, such as intimidation, harassment,
stalking, damage to property, public ridicule, or repeated verbal abuse.
The Supreme Court reiterated that psychological violence does not require physical injury or visible
bruises. The law protects the emotional and mental well-being of women and their children. The
victim’s credible testimony, even without expert psychological evaluation, may be sufficient to prove this
form of violence.

C. "Psychological violence" refers to acts or omissions causing or likely to cause mental or emotional
suffering of the victim such as but not limited to intimidation, harassment, stalking, damage to property,
public ridicule or humiliation, repeated verbal abuse and mental infidelity. It includes causing or allowing
the victim to witness the physical, sexual or psychological abuse of a member of the family to which the
victim belongs, or to witness pornography in any form or to witness abusive injury to pets or to unlawful
or unwanted deprivation of the right to custody and/or visitation of common children.
Sec. 5 (i) Causing mental or emotional anguish, public ridicule or humiliation to the woman or her child,
including, butnot limited to, repeated verbal and emotional abuse, and denial of financial support or
custody of minorchildren of access to the woman's child/children.
Melgar v. People, G.R. No. 223477, February 14, 2018

Facts:
Celso M.F.L. Melgar had a romantic relationship with AAA, which resulted in the birth of their illegitimate
child, BBB. Melgar acknowledged paternity but ceased providing financial support when BBB was about
one year old. AAA filed for support and eventually filed a criminal complaint under Section 5(e) of RA
9262 for economic abuse, alleging that Melgar, despite having the capacity, deliberately failed to support
her and their child, causing them mental and emotional distress.
Initially, a compromise agreement was entered, and the criminal case was provisionally dismissed.
However, the case was revived after Melgar sold a property meant to cover his support arrears. The trial
court and Court of Appeals found him guilty for committing economic abuse.

Issue:
Whether or not Melgar is criminally liable under Section 5(e) of RA 9262 for the deliberate deprivation
of financial support to his common child, BBB.

Ruling: Yes.
The Supreme Court DENIED the petition and AFFIRMED the conviction of Melgar for violation of Section
5(e) of RA 9262. The Court held that:
 Melgar had a legal obligation to support his child;
 He deliberately failed to do so despite capacity;
 His acts constituted economic abuse under RA 9262;
 His claim that he should have been charged under Section 5(i) was unmeritorious, as the
deprivation of support is explicitly punishable under Section 5(e) regardless of psychological
harm.
The Court modified the penalty to include:
 Imprisonment: 6 months (arresto mayor) to 4 years and 2 months (prision correccional)
 Fine: ₱300,000
 Mandatory psychological counseling or psychiatric treatment

Doctrine:
Under Section 5(e) of RA 9262, the deliberate deprivation of financial support to a woman or her child
—especially by a partner or father with the capacity to provide—constitutes economic abuse, a form of
violence against women and their children. This offense is penalized even if no proof of psychological
harm is shown. The act is considered a continuing offense, and its prosecution may proceed even after a
prior dismissal if the conditions of dismissal (e.g., compromise agreement) are violated.
XXX v. People, G.R. No. 255877, March 29, 2023
Facts:
 Petitioner XXX and private complainant AAA were married in 2002. They lived together until
2004 when XXX left the country to work as a seafarer.
 Initially, XXX remitted part of his salary to AAA but eventually stopped. He did not communicate
with AAA for over 13 years.
 AAA claimed that the denial of financial support and abandonment caused her psychological
suffering, mental anguish, and economic difficulty.
 She filed a complaint under Section 5(i) of R.A. 9262 (Anti-Violence Against Women and Their
Children Act), which penalizes psychological violence including denial of financial support that
causes mental or emotional anguish.
 The RTC and CA convicted XXX, finding that his abandonment and failure to support AAA
amounted to economic and psychological abuse under the law.

Issue:
Whether or not XXX is guilty beyond reasonable doubt of violating Section 5(i) of R.A. No. 9262 by
denying financial support to AAA, thereby causing her mental or emotional anguish.

Ruling: No.
 The Supreme Court acquitted XXX.
 It ruled that the elements of willful denial of support and intent to cause mental or emotional
anguish were not proven beyond reasonable doubt.
 Although XXX stopped remitting money, the Court found that:
o He did so due to financial burden from his parents’ medical conditions.
o There was no evidence that he intentionally withheld support to inflict psychological
harm on AAA.
o AAA never communicated with or demanded support from XXX after 2004, despite
knowing he had returned to the country.
o There was no proof that she was financially dependent on him at that time, especially
since she had her own income source.

Doctrine:
 As clarified in Acharon v. People, a violation of Section 5(i) of R.A. 9262 requires the following
elements:
1. The offended party is a woman or her child;
2. There exists a qualifying relationship (spouse, former spouse, dating relationship, etc.);
3. The offender willfully refuses or consciously denies legally due financial support; and
4. The offender does so for the purpose of causing mental or emotional anguish.
 The Court emphasized that:
o Section 5(i) is a mala in se offense — requiring criminal intent.
o Mere failure or inability to provide support does not automatically result in criminal
liability.
 o Intent to inflict mental or emotional harm must be established, not merely inferred
from failure to support.
XXX v. People, G.R. No. 252739, April 16, 2024 (Please double check this case)

𝗙𝗮𝗰𝘁𝘀:
XXX was charged with violating Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and
Their Children Act of 2004) for causing mental and emotional anguish to his wife, AAA, by keeping a
mistress and fathering a child with her. AAA discovered XXX's infidelity through messages and photos
sent by a co-worker, leading to a confrontation where XXX admitted to fathering the child. AAA suffered

𝗥𝗧𝗖 𝗮𝗻𝗱 𝗖𝗔 𝗥𝘂𝗹𝗶𝗻𝗴𝘀:

severe emotional distress, leading to her inability to work and sleep for months.

The Regional Trial Court (RTC) found XXX guilty, sentencing him to imprisonment and ordering him to pay
a fine and undergo psychological counseling. The Court of Appeals (CA) affirmed the RTC's decision,

𝗜𝘀𝘀𝘂𝗲:
emphasizing that XXX's infidelity caused AAA significant mental and emotional anguish.

Whether XXX is guilty of violating Section 5(i) of RA 9262 for causing mental and emotional anguish to

𝗥𝘂𝗹𝗶𝗻𝗴:
his wife through marital infidelity.

𝗬𝗘𝗦, the Supreme Court upheld the lower courts' decisions, ruling that XXX is guilty of violating Section
5(i) of RA 9262. The Court held that marital infidelity constitutes psychological violence under the law,
causing mental and emotional anguish to the aggrieved spouse. The Court emphasized that the act of
infidelity itself is inherently immoral and causes emotional suffering, satisfying the elements of the
crime. The Court rejected XXX's argument that the anguish could have been caused by his refusal to
reconcile, stating that the infidelity was the direct cause of AAA's distress.
Doctrine:
Under Section 5(i) of RA 9262, psychological violence includes acts that cause mental or emotional
anguish to the woman or her child. Marital infidelity, particularly when involving cohabitation and
fathering a child with another woman, is inherently likely to cause such anguish. The law does not
require proof of specific intent to cause harm; it suffices that the victim suffered mental or emotional
anguish due to the offender's actions. This interpretation aligns with the law's purpose of protecting
women and children from violence and threats to their personal safety and security.
XXX v. People, G.R. No. 221370, June 28, 2021

Facts:
Petitioner XXX was charged with violating Section 5(e)(2) of R.A. 9262 (Anti-Violence Against Women
and Their Children Act) for deliberately depriving his wife AAA and their child BBB of financial support.
XXX and AAA were married in March 2005 after AAA became pregnant. Due to marital issues and alleged
abuse, AAA left the conjugal home two months later. In August 2005, she gave birth to BBB, who was
later diagnosed with a congenital condition causing hearing impairment. AAA claimed XXX failed to
provide sufficient support despite repeated pleas for help with their child’s medical and educational
needs. She solely shouldered costs including medical equipment, therapies, and tuition.
XXX denied willful neglect, claiming he was prevented from giving support, had limited income, and that
AAA was manipulative. Evidence showed he only started regular financial support after charges were
filed, and that prior support was sporadic and insufficient.

Issue:
Whether or not XXX is guilty of violating Section 5(e)(2) of R.A. 9262 for economic abuse through the
deliberate deprivation of financial support legally due to his wife and child.

Ruling:
Yes. The Supreme Court affirmed the rulings of the RTC and CA that found XXX guilty beyond reasonable
doubt of economic abuse under Section 5(e)(2) of R.A. 9262. It held that:
 XXX deliberately withheld financial support due to animosity towards AAA.
 His financial assistance only began after the case was filed.
 The sporadic and insufficient support given previously was not in proportion to BBB's needs and
XXX's means.
 The deprivation of support adversely affected AAA and BBB’s wellbeing.
The Court imposed a penalty of six (6) months and one (1) day of prision correccional, a ₱100,000 fine,
₱10,000 moral damages, and ordered mandatory psychological counseling.

Doctrine:
Under Section 5(e)(2) of R.A. 9262, economic abuse includes the deliberate deprivation of financial
support legally due to a woman or her child. Such acts constitute a form of violence against women and
their children when committed with the purpose or effect of controlling or restricting the woman’s or
child’s conduct or wellbeing.
The law recognizes withholding financial support as a continuing offense and a punishable act of
violence, especially when it causes emotional distress and economic hardship to the mother and child.
People v. Genosa, G.R. No. 135981, January 15, 2004

Facts:
Marivic Genosa was charged with parricide for killing her husband, Ben Genosa. Throughout their
marriage, Marivic suffered physical, psychological, and emotional abuse from Ben, including repeated
beatings, verbal abuse, threats, and humiliation. On the night of the killing, a confrontation occurred,
and Marivic struck her husband with a steel pipe while he was asleep.
During the trial, Marivic invoked the battered woman syndrome (BWS) as a defense, claiming that her
mental and emotional state, caused by years of abuse, justified or at least mitigated her act.

Issue(s):
Whether or not Battered Woman Syndrome can justify the killing of an abusive spouse under the claim
of self-defense, even when there is no actual or immediate unlawful aggression at the time of the killing.

Ruling: NO.
The Supreme Court ruled that while Battered Woman Syndrome may affect the mental state of the
victim, self-defense was not applicable in this case because there was no imminent danger or unlawful
aggression at the moment of the killing. Ben was asleep when he was killed.
However, the Court recognized BWS as a legitimate psychological condition and considered it a
mitigating circumstance under Article 13(10) of the Revised Penal Code – as analogous to an illness that
diminishes the exercise of willpower. Thus, Marivic's penalty was reduced.
The Court also acknowledged that BWS could be relevant to determine lack of criminal liability under
appropriate circumstances (e.g., when the threat is imminent), but in this case, the lack of actual
aggression at the time of the act prevented full application of self-defense.

Doctrine:
“Battered woman syndrome” may be considered as a form of self-defense in criminal cases where the
accused is a victim of prolonged domestic abuse.
 For self-defense to be fully appreciated, unlawful aggression must be present at the time of the
killing. Without it, the killing cannot be justified, even in the context of BWS.
 However, BWS may be considered as a mitigating circumstance analogous to an illness diminishing
willpower under Article 13(10) of the Revised Penal Code.
 This case paved the way for legal recognition of BWS in the Philippine legal system, and later helped
shape the provisions of R.A. 9262, which explicitly recognizes BWS.

Significance (in context of R.A. 9262):

While this case predates the enactment of R.A. 9262 (Anti-Violence Against Women and Their Children
Act of 2004), it laid the jurisprudential groundwork for the recognition of battered woman syndrome as
a legitimate psychological condition relevant to criminal defense. The eventual inclusion of BWS under
R.A. 9262, particularly under Section 26, reflects the legal system’s growing sensitivity to the
psychological impacts of domestic abuse on women.
Relation to RA 9262:
Although RA 9262 was enacted in 2004, four years after this decision, the Genosa case became a
landmark precedent in acknowledging the psychological effects of prolonged domestic abuse. The case
strongly influenced the legal and societal understanding of violence against women, which RA 9262 later
codified, including:
 Recognition of psychological violence and emotional abuse.
 Legal acknowledgment of battered woman syndrome as a real and serious consequence of
abuse.
 The law's intent to protect women and children from all forms of violence within intimate or
family relationships.

SECTION 26. Battered Woman Syndrome as a Defense. – Victim-survivors who are found by the courts to
be suffering from battered woman syndrome do not incur any criminal and civil liability notwithstanding
the absence of any of the elements for justifying circumstances of self-defense under the Revised Penal
Code.

People v. Sales, 658 SCRA 367

Facts:
Marivic Sales was charged with the killing of her common-law husband, Allan Acierto. Evidence showed
that for several years, Marivic suffered repeated physical, emotional, and psychological abuse from Allan.
The abuse included beatings, threats, and humiliation, which occurred regularly and intensified over
time. On the night of the incident, after enduring years of abuse, Marivic stabbed Allan while he was
asleep.
At trial, Marivic invoked self-defense, claiming that she suffered from Battered Woman Syndrome (BWS)
and believed that killing Allan was the only way to end the cycle of violence.
A clinical psychologist testified that Marivic exhibited signs consistent with BWS, including learned
helplessness, constant fear, and a distorted perception of danger due to prolonged abuse.

Issue:
Whether the Battered Woman Syndrome be considered a valid defense under R.A. 9262 in a case where
the accused killed her abuser while he was not attacking her at the time of the killing?

Ruling:
Yes. The Supreme Court ruled that Battered Woman Syndrome, as defined under Section 26 of R.A.
9262, can be a valid defense in homicide or parricide cases involving abused women. The Court
considered the psychological impact of prolonged abuse on the mental state of the victim.
Although Allan was not attacking Marivic at the exact moment she stabbed him, the Court recognized
that a battered woman does not necessarily respond to danger in the same way as a typical person. Her
perception of threat and the need to protect herself are shaped by the ongoing pattern of abuse.
The Court acquitted Marivic Sales, ruling that she acted out of a state of fear and psychological paralysis
due to the cycle of violence she had endured. The BWS explained her actions and established that her
mental state justified her belief in the necessity of the act.
Doctrine:
Battered Woman Syndrome (BWS) may be invoked as a defense under R.A. 9262 in criminal cases
where the accused woman commits an act punishable under the Revised Penal Code or special laws as a
result of abuse. Courts must consider the unique psychological effects of prolonged abuse and not apply
traditional notions of self-defense rigidly.
The elements of self-defense can be interpreted in the context of BWS, particularly regarding unlawful
aggression and reasonable necessity, based on the battered woman’s perception of threat shaped by
her experiences.

While the case primarily deals with parricide and the limits of parental discipline, it does not directly
address Battered Woman Syndrome (BWS). However, the Court's discussion on the limits of acceptable
behavior within familial relationships can be analogously applied to situations involving BWS, where
prolonged abuse may lead to psychological trauma and, in some cases, criminal acts committed by the
victim against the abuser.

AAA vs. BBB, G.R. 212448, January 11, 2018

Facts:
AAA and BBB were married and had children. During the course of their marriage, BBB engaged in an
extramarital affair with another woman. AAA claimed that BBB's infidelity caused her emotional and
psychological suffering, which adversely affected her well-being and the welfare of their children.
AAA filed a complaint under Section 5(i) of R.A. 9262, asserting that BBB’s acts of marital infidelity and
abandonment constituted psychological violence under the law. The lower courts dismissed the case,
concluding that infidelity, in and of itself, was not sufficient to establish a violation of R.A. 9262 without
concrete proof of the psychological impact on the woman.

Issue:
Whether or not BBB’s act of infidelity constitutes psychological violence punishable under R.A. 9262.

Ruling:
Yes. The Supreme Court ruled in favor of AAA. It held that marital infidelity may amount to
psychological violence as defined under Section 5(i) of R.A. 9262, if it causes emotional and
psychological suffering to the woman or her child.
The Court emphasized that it is not the act of infidelity alone that is punishable, but its effect on the
mental or emotional state of the victim. AAA was able to present sufficient evidence, including her
testimony and medical records, showing that she suffered emotional anguish and psychological distress
because of BBB’s infidelity.

Doctrine:
Under Section 5(i) of R.A. 9262, psychological violence includes acts causing or likely to cause emotional
suffering, including marital infidelity. What is punishable is not merely the act of cheating but the
resulting psychological or emotional abuse inflicted on the woman or her child.
“Marital infidelity, as a form of psychological violence under Section 5(i) of R.A. 9262, is penalized not for
being immoral or contrary to public policy, but because it causes emotional or psychological suffering
on the part of the woman or her children.”

Knutson vs. Sarmiento-Flores, G.R. No. 239215. July 12, 2022

Facts:
Randy Michael Knutson married Rosalina Sibal Knutson and had a daughter, Rhuby. They lived in the
Philippines but later separated due to Rosalina’s infidelity. Rosalina became addicted to gambling,
incurred large debts, sold family assets, and exposed Rhuby to her lovers, abuse, and drug-related
activities.
Randy alleged that Rosalina physically and psychologically abused Rhuby, including slapping her, pulling
her hair, and threatening to kill her. He filed a petition under R.A. 9262 seeking protection and custody
orders on behalf of Rhuby.
The RTC dismissed the case, ruling that a mother cannot be an offender under R.A. 9262, and that the
remedies are only available to women victims. Randy’s motion for reconsideration was denied, leading
him to file a Petition for Certiorari before the Supreme Court.
Randy alleged that Rosalina committed acts of psychological violence against Rhuby by engaging in
extramarital affairs, bringing her lovers into their conjugal home, and exposing their daughter to such
inappropriate behavior.
Rosalina openly had a boyfriend, causing emotional and psychological distress to Rhuby. Randy warned
her to be discreet for their daughter’s sake, but Rosalina disregarded him. Her infidelity, along with her
neglect and erratic behavior, allegedly contributed to an abusive environment.
The petition was filed before the Regional Trial Court (RTC) Branch 69 of Taguig City, which dismissed
the case. The RTC ruled that the acts complained of did not amount to a violation of R.A. 9262. The court
reasoned that infidelity alone does not constitute psychological violence against a child under the law
and that a mother cannot be an offender under R.A. 9262.
Randy, acting on behalf of his daughter, elevated the case to the Supreme Court, arguing that the RTC
gravely abused its discretion in dismissing the case.

Issue:
Whether a mother’s infidelity and exposure of her child to such acts can be considered psychological
violence under R.A. 9262, thereby justifying the issuance of a protection order.

Ruling: Yes.
The Court held that the repeated exposure of a minor to a parent’s infidelity and inappropriate
behavior, especially within the confines of the conjugal home, can inflict emotional and psychological
trauma on the child. This constitutes psychological violence under Section 5(i) of R.A. 9262.
According to the Court, actual physical harm is not necessary to prove psychological violence. The
emotional suffering of the child, arising from the parent’s wrongful acts, is sufficient.
Thus, the Supreme Court remanded the case to the RTC for further proceedings and directed it to
consider the issuance of a protection order in favor of the child.

Doctrine:
Infidelity, when committed in a manner that repeatedly exposes a child to sexual or emotionally
inappropriate behavior of a parent, may amount to psychological violence under R.A. 9262. Emotional
and psychological suffering need not arise from physical abuse alone. The law protects not only the
physical well-being of women and children but also their emotional and mental health.