Jaime J. Araza vs. People of the Philippines, G.R. No. 247429, September 08, 2020

Facts:
Complainant testified that she and Accused were married on October 5, 1989 at Malate Catholic Church. She had no marital issues with Accused until he went to Zamboanga City for their networking business. Accused was formerly working as an Overseas Filipino Worker but decided to stop in 1993 to join complainant in her business.

One day, she received a text message informing her that her accused-husband is having an affair with their best friend. At first, she did not believe them. However, that information brought complainant to Zamboanga to see for her herself whether it was true. Indeed she was able to confirm that her husband was living with another woman.

She instituted a complaint against the accused and his alleged mistress for Concubinage at the Philippine National Police. The case was subsequently amicably settled after the parties executed an Agreement whereby accused and mistress committed themselves never to see each other again.

After the case was settled accused lived with complainant. However, it was only for a short time. Without saying a word, accused left complainant. She was looking for the accused and out of desperation, she sought the help of the NBI to search for him. To her surprise, the accused had returned to live with his mistress again.

The complainant went emotionally depressed and anxious She was suffering from insomnia and asthma. Allegedly, she is still hurting and crying. She is took anti-depressant and sleeping pills to cope with her severe emotional and psychological turmoil brought about by the accused marital infidelity and having children with his mistress.

A case was filed against the accused for Violence Against Women and their Children on Psychological Violence caused by his infidelity. RTC found accused guilty of the said offense. Accused appeal the case to the CA to which it affirmed the decision of the RTC in toto.

Issue:
Whether the CA erred in ruling that Araza committed psychological violence upon his wife AAA by committing marital infidelity, which caused AAA to suffer emotional anguish and mental suffering.

Held:
Yes, Psychological violence is an indispensable element of violation of Section 5(i) of R.A. No. 9262. Equally essential is the element of emotional anguish and mental suffering, which are personal to the complainant. Psychological violence is the means employed by the perpetrator, while emotional anguish or mental suffering are the effects caused to or the damage sustained by the offended party. The law does not require proof that the victim became psychologically ill due to the psychological violence done by her abuser. Rather, the law only requires emotional anguish and mental suffering to be proven. To establish emotional anguish or mental suffering, jurisprudence only requires that the testimony of the victim to be presented in court, as such experiences are personal to this party.

In order to establish psychological violence, proof of the commission of any of the acts enumerated in Section 5(i) or similar of such acts, is necessary.

The prosecution has established Araza’s guilt beyond reasonable doubt by proving that he committed psychological violence upon his wife by committing marital infidelity. AAA’s testimony was strong and credible. She was able to confirm that Araza was living with another woman. Marital infidelity, which is a form of psychological violence, is the proximate cause of AAA’s emotional anguish and mental suffering, to the point that even her health condition was adversely affected.

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