MANILA— The Supreme Court (SC) has acquitted a woman convicted of parricide for killing her husband, ruling that battered woman syndrome (BWS) may serve as a justifying circumstance under the Anti-Violence Against Women and Their Children Act.

In a 16-page decision penned by Senior Associate Justice Marvic Leonen, the SC Second Division recognized the repeated physical abuse suffered by the woman and applied Section 26 of Republic Act No. 9262, or the Anti-Violence Against Women and Their Children Act of 2004.

The woman shot her husband several times with a 9mm pistol in 2011, killing him immediately. The couple had been married for 11 years and had three sons at the time.

Court records showed that their relationship had deteriorated after the woman suspected her husband of having an affair. She testified that she once followed him and saw him pick up a female passenger on his motorcycle. On another occasion, an anonymous caller told her that her husband was at a hotel, where she found him in bed with another woman.

The woman also testified that her husband became physically abusive after an incident in which he restrained her while another woman attacked her. She said he would often come home drunk and beat her with his bare hands, at times about four times a week.

On February 8, 2011, she found her husband shouting at their children. When he saw her, he allegedly began throwing objects around the house and hurled their two-year-old son onto a chair.

She struck him on the head with a ladle before going outside to seek help from a neighbor, who advised her to settle the dispute by talking to her husband.

However, when she tried to speak with him, he allegedly hurled insults at her. At around 8 p.m., as she packed her belongings to leave, her husband threatened that they would not leave the house alive, beat her, and slammed her head against a wall.

The woman said her vision dimmed and she lost her memory. She regained consciousness at a police station.

She presented a government psychiatrist and another physician who assisted in diagnosing her with battered woman syndrome.

The Regional Trial Court convicted her of parricide in 2020 and sentenced her to reclusion perpetua. The Court of Appeals later affirmed the ruling, finding that she had failed to establish self-defense arising from BWS, prompting her to appeal to the SC.

In reviewing the case, the high court considered the psychiatric report and the woman’s account of repeated abuse, including what she described as two cycles of violence.

She argued that the second episode of acute battering occurred when her husband slammed her head against the wall, prompting her to act in self-defense and protect her children.

SC explains battered woman syndrome

In acquitting the woman, the SC cited the landmark case of People v. Genosa, which recognized battered woman syndrome as a psychological condition arising from domestic abuse.

The condition involves a cycle of violence consisting of three phases: tension-building, acute battering, and a nonviolent phase. The Court explained that a woman may be considered battered when she experiences this cycle at least twice.

It also cited RA 9262, which recognizes BWS as a scientifically defined pattern of psychological and behavioral symptoms resulting from cumulative abuse in a battering relationship.

Under ordinary self-defense rules, an accused must establish unlawful aggression, reasonable necessity of the means used to prevent or repel it, and lack of sufficient provocation.

However, Section 26 of RA 9262 provides that victims who are found to be suffering from BWS shall not incur criminal or civil liability, even if the elements of self-defense are absent.

The SC explained that lawmakers recognized that the experiences of battered women do not always conform to the traditional concept of physical confrontation under self-defense doctrine.

It noted that the woman had endured more than two years of abuse but remained with her husband because she feared retaliation and distrusted law enforcement, as he was a police officer. Her isolation was compounded by the fact that her neighbors included her sister-in-law and her husband’s colleague.

“Given the duration of the abuse and the severity of the assaults she had sustained, this Court finds that the violence perpetrated by [the husband] against accused-appellant were not isolated incidents but a systemic pattern,” the Supreme Court said.

“This fundamentally altered accused-appellant’s state of mind and caused her to have learned helplessness that led her to believe that only killing her husband would free her,” it added.

The high court reminded trial courts to interpret RA 9262 with an understanding of the circumstances that led to its enactment, emphasizing that the law seeks to protect women trapped in cycles of violence that conventional criminal doctrines may not fully account for.

“To deny the accused the protection of Section 26 simply because her abuse was not perfectly documented would be to impose upon battered women a burden the law itself never intended,” it stressed.