MANILA, Philippines — The Supreme Court (SC) has clarified that a psychological evaluation is not required to prove psychological violence under Republic Act No. 9262, or the Anti-Violence Against Women and Their Children (VAWC) Act.  

In a decision penned by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division upheld the conviction of a man, whose name was not disclosed, for causing psychological violence to his wife and children.  

The case stemmed from the accused’s extramarital affair, abandonment of his family, and failure to provide financial support for his children. 

The lower courts ruled that all elements of psychological violence under Section 5 (i) of the Anti-VAWC Act were present: 

(1) the victim is a woman and/or her child

(2) the victim is the wife or has a relationship with the offender

(3) the offender causes the victim mental or emotional anguish;

(4) the anguish is caused through public humiliation, verbal and emotional abuse, denial of financial support, or similar acts.  

Challenging the decision, the accused argued that “to prove the element of mental or emotional anguish, the prosecution must show a psychological report to establish psychological violence.” 

However, the high court ruled that such a report is unnecessary, emphasizing that “a psychological evaluation from an expert witness is not necessary to prove psychological violence; the victim’s testimony is sufficient to prove emotional or mental suffering.”

The SC found the wife’s detailed testimony credible, as she recounted how the accused left their home to live with another woman next door, fathered a child with her, and flaunted his affair on social media. Her testimony established the mental and emotional anguish she endured.  

The accused was sentenced to up to eight years in prison, fined  P200,000, and ordered to pay P75,000 in damages. 

The SC also ordered him to undergo psychological counseling or psychiatric treatment.