TL;DR

The Supreme Court acquitted XXX of violating the Anti-Violence Against Women and Children Act (VAWC) for failing to provide financial support to his child. The Court ruled that while non-support occurred, the prosecution failed to prove psychological violence and emotional anguish caused by willful denial of support. Crucially, the Court accepted expert testimony that XXX suffered from Post-Traumatic Stress Disorder (PTSD) and paranoid ideations stemming from his wife’s actions, rendering him mentally incapacitated and unable to work, thus negating the element of intentional deprivation required for conviction under Section 5(i) of R.A. 9262. This decision highlights that mental illness can be a valid defense in VAWC cases where intent is a critical element of the crime.

When Trauma Becomes a Shield: Can Mental Illness Excuse Non-Support Under VAWC?

In a case that navigates the intersection of family law, criminal law, and mental health, the Supreme Court was tasked to determine if XXX was rightfully convicted for violating Section 5(i) of Republic Act No. 9262, the Anti-Violence Against Women and Children Act of 2004. This section penalizes causing mental or emotional anguish to a woman and/or child through acts including the denial of financial support. The prosecution argued that XXX willfully deprived his wife and child of financial support, causing them mental and emotional distress. XXX, on the other hand, claimed that his failure to provide support was not willful but stemmed from Post-Traumatic Stress Disorder (PTSD), rendering him incapable of working. The lower courts convicted him, finding his defense unconvincing. The pivotal question before the Supreme Court was whether XXX’s mental state negated the element of psychological violence required for a conviction under Section 5(i) of R.A. 9262.

The Supreme Court began its analysis by emphasizing the distinct nature of Section 5(i) of R.A. 9262. Unlike other forms of VAWC, Section 5(i) specifically targets psychological violence as the means and emotional anguish or mental suffering as the resulting harm. Citing Dinamling v. People, the Court reiterated that the focus is on the “causation of non-physical suffering.” The prosecution bears the burden of proving all elements of the crime beyond reasonable doubt. In this case, while the fact of non-support was established, the crucial elements of psychological violence and causation of emotional distress were contested. The Court scrutinized the evidence presented by both sides, particularly focusing on the testimony regarding XXX’s mental health.

The prosecution presented the testimony of XXX’s wife, AAA, and her sister, BBB, to establish the deprivation of financial support and the resulting emotional distress. AAA testified that XXX stopped providing support in 2005, causing her and their child significant hardship and dependence on her sister. BBB corroborated this, detailing the financial strain and AAA’s emotional state. However, the defense countered with expert testimony from a licensed counseling psychologist, Jesselyn Mortejo, who diagnosed XXX with PTSD. Mortejo testified that XXX’s condition, triggered by his tumultuous relationship with AAA, led to “pronounced avoidance symptoms” and “paranoid ideations” that incapacitated him from working. She clarified that while not insane, XXX’s PTSD significantly impaired his cognitive ability to function normally in a work environment.

The Supreme Court gave significant weight to the expert testimony, noting that it provided a credible explanation for XXX’s inability to provide support. The Court highlighted XXX’s attempts to negotiate support, offering what he could afford, which were refused by AAA. This indicated a lack of willful intent to cause psychological violence. Moreover, the Court underscored the psychologist’s finding that XXX’s PTSD and paranoia were directly linked to AAA’s actions, including “public humiliation, physical violence, and threats.” The Court stated:

“Here, the evidence shows that petitioner could not provide support because: (1) AAA prevented him from doing so by refusing what he could offer; and (2) he was suffering from an incurable mental illness which, though not sufficient to be considered a form of insanity, was to a degree that effectively incapacitated him from earning.”

The Court distinguished between “failing to provide” and “denying” support, emphasizing that “denying” implies a willful intent. In XXX’s case, the evidence pointed to incapacity due to mental illness rather than a deliberate intent to cause psychological violence. The Court rejected the lower court’s reliance on XXX’s physical appearance and ability to hire a lawyer as proof of capacity to work, finding these observations insufficient to overcome the expert medical evidence. Furthermore, the Supreme Court clarified the distinction between economic abuse and psychological violence, disagreeing with the Office of the Solicitor General’s (OSG) argument that economic abuse automatically equates to psychological violence under Section 5(i). Citing Melgar v. People, the Court reiterated that economic abuse is penalized under Section 5(e) of R.A. 9262, not Section 5(i), which specifically requires proof of psychological violence and emotional anguish.

Ultimately, the Supreme Court concluded that the prosecution failed to prove beyond reasonable doubt that XXX’s failure to provide support constituted psychological violence or caused AAA’s emotional distress. The Court recognized that while non-support occurred, the lack of willful intent due to XXX’s mental incapacity, supported by expert testimony, warranted acquittal. This decision underscores the importance of considering mental health in VAWC cases, particularly when intent is a critical element of the offense. It sets a precedent that mental illness, when properly substantiated, can serve as a valid defense against charges under Section 5(i) of R.A. 9262, highlighting the need for a nuanced understanding of psychological violence within the context of VAWC.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.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: XXX vs. People, G.R. No. 252087, February 10, 2021