The Supreme Court affirmed the conviction of BBB255466 for psychological violence against his common-law partner and acts of lasciviousness against his daughter. This ruling underscores the importance of protecting women and children from abuse, clarifying what constitutes psychological violence under Republic Act No. 9262 and acts of lasciviousness under the Revised Penal Code, as related to Republic Act No. 7610. It reinforces that emotional and psychological harm, alongside physical abuse, are serious offenses with significant legal consequences, ensuring victims receive protection and justice.

Beyond Physical Wounds: Can Emotional and Psychological Abuse Constitute Criminal Acts?

This case revolves around BBB255466, who faced charges for violating Republic Act No. 9262 for psychological violence against his partner, CCC, and Republic Act No. 7610 for acts of lasciviousness against his daughter, AAA. The accusations painted a picture of repeated abuse and exploitation within a familial context. The central legal question was whether the evidence presented sufficiently proved that BBB255466 committed these acts, causing significant emotional and psychological harm to the victims, thus warranting a conviction under Philippine law.

The facts presented by the prosecution detailed a troubling history. BBB255466 and CCC were common-law partners since 2003, and their relationship was allegedly marred by repeated instances of physical and verbal abuse. CCC testified to incidents where BBB255466 threatened her with violence, including wielding a bolo and attempting to harm her with a liquefied petroleum gas tank. Furthermore, he was accused of acts of lasciviousness against their daughter, AAA, who was seven years old at the time of the alleged incidents. These accusations prompted the filing of separate criminal cases against BBB255466.

The Regional Trial Court (RTC) found BBB255466 guilty on both counts, leading to his appeal to the Court of Appeals (CA). The CA affirmed the RTC’s decision, emphasizing the credibility of the witnesses and the weight of the evidence presented. Dissatisfied with the CA’s ruling, BBB255466 elevated the case to the Supreme Court, arguing that the prosecution failed to adequately prove the elements of psychological violence and acts of lasciviousness. The Supreme Court then took on the responsibility of determining whether the lower courts erred in their assessment and application of the law.

The Supreme Court anchored its decision on the provisions of Republic Act No. 9262, also known as the Violence Against Women and Their Children Act. Section 5(i) of this Act criminalizes causing mental or emotional anguish, public ridicule, or humiliation to a woman or her child. The court emphasized that psychological violence, as defined in Section 3(c) of the same Act, includes acts or omissions that cause or are likely to cause mental or emotional suffering to the victim. The Supreme Court also referred to Article 336 of the Revised Penal Code, in conjunction with Republic Act No. 7610, which addresses acts of lasciviousness committed against children.

The Supreme Court, in its analysis, meticulously examined the evidence presented concerning the charge of psychological violence. The Court found that the prosecution successfully established that BBB255466 committed acts of repeated physical and verbal violence against CCC, causing her significant mental and emotional anguish. The court highlighted CCC’s testimony, which detailed the threats, insults, and controlling behaviors of BBB255466, all intended to inflict suffering upon her. It also underscored the importance of the victim’s testimony in cases involving psychological violence, as it provides direct evidence of the abuser’s behavior, intent, and the resulting harm.

Regarding the charge of acts of lasciviousness, the Supreme Court focused on the age of the victim, AAA, who was seven years old at the time of the alleged incidents. It emphasized that under Article 336 of the Revised Penal Code, in relation to Section 5(b) of Republic Act No. 7610, any act of lasciviousness committed against a child under twelve years of age is a serious offense. The Court found that the prosecution presented sufficient evidence to prove that BBB255466 touched AAA’s vagina and made her hold his penis, constituting acts of lasciviousness within the purview of the law. The Court further highlighted the moral ascendancy and influence that BBB255466, as AAA’s father, had over her, making her unable to give rational consent to his sexual advances.

The Supreme Court ultimately held that the Court of Appeals did not err in affirming BBB255466’s conviction for psychological violence and acts of lasciviousness. The Court emphasized that its role is not to re-evaluate the factual findings of lower courts, especially when supported by substantial evidence. Instead, it focused on ensuring that the lower courts correctly applied the relevant laws and jurisprudence. The decision reinforced the importance of protecting women and children from abuse, clarifying what constitutes psychological violence under Republic Act No. 9262 and acts of lasciviousness under the Revised Penal Code, as related to Republic Act No. 7610.

In assessing the penalties, the Supreme Court made some modifications to align with existing laws and jurisprudence. For the crime of psychological violence, the Court imposed an indeterminate sentence of six months and one day of prision correccional, as minimum, to eight years and one day of prision mayor, as maximum. It also ordered BBB255466 to pay a fine of PHP 100,000.00 and undergo mandatory psychological counseling or psychiatric treatment. For the crime of acts of lasciviousness, the Court imposed an indeterminate penalty of 12 years and one day of reclusion temporal as minimum to 17 years and four months of reclusion temporal as maximum. It also ordered BBB255466 to pay a fine of PHP 15,000.00, PHP 50,000.00 as civil indemnity, PHP 50,000.00 as moral damages, and PHP 50,000.00 as exemplary damages.

This decision clarifies the scope and application of laws designed to protect women and children from abuse. By upholding the conviction of BBB255466, the Supreme Court sent a clear message that emotional and psychological harm, alongside physical abuse, are serious offenses with significant legal consequences. The ruling provides a framework for future cases involving similar issues, ensuring that victims receive the protection and justice they deserve. It also underscores the importance of addressing all forms of abuse, including those that may not leave visible physical marks but can have devastating and long-lasting effects on the victims’ mental and emotional well-being.

The Court also noted the importance of intent in psychological violence cases. To secure a conviction under Section 5(i) of Republic Act No. 9262, prosecutors must prove that the accused willfully or intentionally caused mental or emotional anguish, public ridicule, or humiliation to the victim. It is not enough to simply show that the victim experienced such anguish; the prosecution must demonstrate that the accused consciously committed the acts complained of for the purpose of inflicting said anguish. This underscores the importance of evidence that directly links the accused’s actions to the specific intent of causing psychological harm.

Finally, the Supreme Court emphasized the necessity of considering the victim’s perspective and judgment at the time of the commission of the crime, particularly in cases involving acts of lasciviousness against children. The Court recognized that children are especially vulnerable to abuse due to their age, size, and dependence on adults. As such, any act of lasciviousness committed against a child, even without explicit force or intimidation, is deemed a serious violation of their rights. The Court’s decision serves as a reminder of the need to protect children from all forms of sexual abuse and exploitation, and to hold perpetrators accountable for their actions.

FAQs

What was the key issue in this case?	The key issue was whether the evidence presented sufficiently proved that BBB255466 committed acts of psychological violence against his partner and acts of lasciviousness against his daughter, thus warranting a conviction under Philippine law.
What is psychological violence under Republic Act No. 9262?	Psychological violence refers to acts or omissions that cause or are likely to cause mental or emotional suffering to the victim, including intimidation, harassment, stalking, public ridicule, repeated verbal abuse, and denial of financial support.
What are acts of lasciviousness under the Revised Penal Code, as related to Republic Act No. 7610?	Acts of lasciviousness are lewd or indecent acts committed with the intent to arouse or gratify the sexual desire of a person. When committed against a child under twelve years of age, it is considered a serious offense under Philippine law.
What is the significance of the victim’s testimony in cases involving psychological violence?	The victim’s testimony is crucial because it provides direct evidence of the abuser’s behavior, intent, and the resulting harm. It sheds light on the emotional and psychological impact of the abuse, which is essential in proving the elements of psychological violence.
What factors did the Supreme Court consider in determining whether BBB255466 committed acts of lasciviousness against his daughter?	The Supreme Court considered the age of the victim (AAA), the nature of the acts committed by BBB255466, and the moral ascendancy and influence he had over her as her father. It emphasized that AAA, being a child, could not give rational consent to his sexual advances.
What penalties were imposed on BBB255466 for the crimes he committed?	For psychological violence, BBB255466 was sentenced to an indeterminate penalty of six months and one day of prision correccional to eight years and one day of prision mayor, ordered to pay a fine of PHP 100,000.00, and undergo mandatory psychological counseling. For acts of lasciviousness, he was sentenced to an indeterminate penalty of 12 years and one day of reclusion temporal to 17 years and four months of reclusion temporal, ordered to pay a fine of PHP 15,000.00, PHP 50,000.00 as civil indemnity, PHP 50,000.00 as moral damages, and PHP 50,000.00 as exemplary damages.
What message did the Supreme Court send through its decision in this case?	The Supreme Court sent a clear message that emotional and psychological harm, alongside physical abuse, are serious offenses with significant legal consequences. The ruling reinforces the importance of protecting women and children from abuse and holding perpetrators accountable for their actions.
What is the role of intent in cases of psychological violence under Republic Act No. 9262?	To secure a conviction under Section 5(i) of Republic Act No. 9262, the prosecution must prove that the accused willfully or intentionally caused mental or emotional anguish, public ridicule, or humiliation to the victim. The prosecution must demonstrate that the accused consciously committed the acts complained of for the purpose of inflicting said anguish.

This landmark case underscores the Philippines’ commitment to protecting women and children from all forms of abuse. The Supreme Court’s decision serves as a reminder that emotional and psychological harm are just as damaging as physical violence, and that perpetrators of such abuse will be held accountable under the law. The ruling provides a valuable framework for future cases, ensuring that victims receive the protection and justice they deserve.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: BBB255466 v. People, G.R. No. 255466, November 27, 2024