Daily TribuneEvidence adduced must be closely examined under the lens of a judicial microscope to ensure that conviction only flows from moral certainty that guilt has been established by proof beyond reasonable doubt.
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Remember my article last week? It spoke about the evidence, both in quantum and in kind, necessary to convict an accused of psychological violence under the VAWC law. Applying those parameters to the present case, the Supreme Court ruled in favor of the accused.
Here is its discussion:
“To recall, the Information stated that AAA’s mental and emotional anguish, humiliation, anxiety, and depression were caused by the following acts committed by Caridaoan sometime in February 2010: (1) purposely carrying on an affair with Michelle and flaunting their relationship to AAA ... However, based on the evidence on record, the Court is not convinced that Caridaoan committed these acts. As the Court sees it, nothing about the events that transpired in February 2010 or even thereafter conclusively establishes that Caridaoan engaged in an intimate relationship with Michelle and flaunted it to AAA, as the Information alleges.
“Considering their living arrangement, seeing Caridaoan and Michelle together in their apartment or at work is not proof beyond reasonable doubt of the acts complained of. To the mind of the Court, what undoubtedly stands out, even from the prosecution’s own version of the events, is that during this period, Caridaoan confessed to AAA his intention to be with Michelle; and it was only after such confession that Caridaoan left AAA, stayed and lived with Michelle, and later married the latter.
“These are acts that are not part of, and are even contrary to, the allegations in the Information.
“Second, the prosecution’s evidence failed to establish that Caridaoan intended to cause AAA mental or emotional anguish, public ridicule, or humiliation. On the contrary, the records of the case support Caridaoan’s defense of good faith. It is settled that in crimes mala in se, good faith and lack of criminal intent are available defenses. This is because in such crimes, the penal act is punished only when the person committing it is morally blameworthy.
“On the other hand, if a person commits the actus reus without intending any wrongdoing, then there is no mens rea that can fulfill the elements of the crime pertaining to intent. For a violation of Section 5(i), the requisite criminal intent, or mens rea, is ‘causing mental or emotional anguish, public ridicule, or humiliation’ upon the woman and/or her child.
“It is undisputed that despite leaving AAA and marrying Michelle, Caridaoan never abandoned AAA. Instead, he continued to provide support and assistance to AAA as she recovered from her heart operation. In her testimony, AAA herself admitted that while Caridaoan did not visit her at the hospital during the surgery, he helped her with the finances. AAA narrated that, to finance her surgery, she sold a vehicle co-owned by Caridaoan. Caridaoan, however, did not get his share of the proceeds from the sale and let AAA keep the money for her medical needs.
“Apart from this, as earlier discussed, AAA confirmed that during her recovery, Caridaoan regularly bought her medicines and food, or anything that she would ask him to bring. He also gave AAA her share of the income from their business and helped her hire a personal helper, named Lanie, who took care of her during her recovery.
“Lastly, there is reasonable doubt that AAA’s mental and emotional distress was caused by or directly attributable to the alleged acts of Caridaoan. While the prosecution has shown that AAA experienced mental and emotional distress, AAA’s Psychological Report did not categorically establish that her high level of anxiety and depression was directly attributable to Caridaoan’s act of flaunting his relationship with Michelle to AAA or excluding AAA from the income and affairs of the business.
“The report simply stated that AAA ‘exhibits considerable hostile feelings and aggressive impulses which are possibly directed to her live-in partner and secretary,’ and that her emotional functioning, characterized by a high level of anxiety, hostility, weakness, and low self-esteem, may have been brought about by her reported experience of being left by her live-in partner in favor of another woman.
“Evidence adduced must be closely examined under the lens of a judicial microscope to ensure that conviction only flows from moral certainty that guilt has been established by proof beyond reasonable doubt.
“In this case, the evidence of the prosecution did not meet the quantum of evidence necessary for conviction. The prosecution fell short of proving that Caridaoan willfully and deliberately caused AAA mental or emotional anguish, public ridicule, or humiliation through the acts alleged in the Information.
“Truly, ending a relationship is heartbreaking and causes one to experience, among other things, emotional distress, anxiety and depression. However, the fact that a woman experiences mental or emotional distress in a relationship does not automatically translate into a crime of psychological violence and criminal liability under Republic Act 9262.
“Emotional anguish and mental distress experienced in intimate relationships are not the gravamen of the crime. What gives rise to criminal liability under Republic Act 9262 is the offender’s act of deliberately and willfully causing a woman mental or emotional anguish, public ridicule, or humiliation, which the prosecution failed to prove in this case.”
The facts and the redacted quoted portion of the decision are from SC G.R. 228741 (23 April 2025).
