Supreme Court/File
Supreme Court/File

MANILA — The Supreme Court of the Philippines has acquitted a man previously convicted of psychological violence under Republic Act No. 9262, ruling that the prosecution failed to prove that the complainant suffered mental or emotional anguish.

In a 3-2 decision, the Court’s Third Division reversed the ruling of the Court of Appeals of the Philippines, which earlier upheld the conviction of the accused for violating the Anti-Violence Against Women and Their Children Act of 2004.

The 21-page ruling, penned by Associate Justice Henri Jean Paul Inting, stemmed from a complaint filed by the accused’s girlfriend, who alleged that she received text messages demanding sexual intercourse and threatening her life if she refused.

The complainant said she endured emotional abuse throughout their nearly four-year relationship, claiming the accused blackmailed her and threatened to release her nude photos and a sex video. She later sought police assistance after the accused allegedly demanded money in exchange for not posting the video.

Authorities attempted an entrapment operation, which initially failed when the suspect did not appear. A second operation led to his arrest after he received PHP2,000.

Criminal complaints for grave threats under Article 282 of the Revised Penal Code and violation of the Anti-VAWC law were subsequently filed. The accused denied the allegations, asserting that the charges were filed out of vengeance, and claimed the complainant’s parents disapproved of their relationship.

The Regional Trial Court found him guilty of violating Section 5(i) of the Anti-VAWC Act, a decision later affirmed by the appellate court, prompting him to elevate the case to the High Court.

In its ruling, the Supreme Court said there was insufficient evidence to establish that the accused acted with intent to cause psychological harm.

It also found the complainant’s behavior inconsistent with claims of distress, noting that she continued to interact with the accused after the alleged threats.

“Her behavior after receiving the text messages does not show there was substantial distress on her part. For one, AAA even boarded [the accused]’s motorcycle shortly after the incident. If, indeed, AAA was afraid for her life, she would not have boarded the motorcycle, considering that she was already with the police officers during the alleged entrapment operations.”

The Court also examined the content of the text messages and found no clear indication that the accused intended to inflict emotional harm.

“These circumstances imply, if not show, that the two were in good terms at the time of the conversation and lend more credence to the conclusion that the two text messages sent by the accused were out of anger and not out of a specific intent to cause distress,” the Supreme Court said.

The Court likewise cited the complainant’s social media posts, including one captioned “Nagmahal, nasaktan, nagpakulong,” and another showing the accused in detention with the statement, “Diba ang saya mo na. Lol,” which it said did not reflect the behavior of a victim of abuse.

“Thus, the foregoing circumstances all give rise to the conclusion that the case of AAA and XXX is not one for psychological violence but merely that of a private quarrel between the couple, not within the ambit of what is sought to be punished by Republic Act 9262,” the Supreme Court added.

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