29/05/2026
The Supreme Court Speaks: Crime of violence against women through harassment requires a present or past sexual or dating relationship and acts of harassment causing alarm or substantial emotional or psychological distress
In Janito M. Sedenio vs. People of the Philippines, January 19, 2026, Sedenio and the offended party, “AAA,” were in a romantic and sexual relationship for approximately two years, despite both of them being married to other persons. The relationship eventually mellowed in early 2011, when AAA revealed that she had another partner, “YYY.”
During the period of February to August 2012, Sedenio sent AAA a series of threatening, humiliating, and derogatory text messages that included threats to burn the belongings of her new partner, threats to harm her mother, accusations of embezzlement, mocking her reputation, and threats to release photographs of the two of them unclothed in bed to humiliate her. Sedenio also forcibly entered AAA’s home with a kitchen knife. Because of this, AAA has experienced mental anguish and sleepless nights for 6 months, eventually resulting in a besmirched reputation.
The Regional Trial Court found Sedenio guilty of violating Sec. 5(h)(5) of R.A. 9262, with the decision affirmed by the Court of Appeals. Sedenio appealed to the Supreme Court, arguing that the text messages were not authenticated and, furthermore, that AAA’s distress was not proven by any medical or psychological report.
The Supreme Court denied Sedenio’s petition and affirmed his conviction. The Court states that, under the Rules on Electronic Evidence, the text messages provided by AAA were admissible as evidence if the testimony of a party to the conversation or a person with personal knowledge of it was offered. AAA, as the recipient of the text messages, provided this testimony, bolstered by Sedenio’s own judicial admission during the trial, where he stated that he sent “humiliating and threatening words” because he felt hurt. The Court clarifies that for Sec. 5(h)(5) of R.A. 9262 to apply in a case, it is immaterial whether the parties were still in a relationship at the time the information was filed; it is already sufficient that a past or present dating or sexual relationship existed when the said acts were committed. The Court also held that the victim’s testimony was sufficient to establish emotional or psychological distress. In cases of psychological violence, according to the Court, proof that the victim became psychologically ill as a result of the sustained psychological violence is not required; thus, the jurisprudence requires their unique testimony to be presented to the court to prove their emotional anguish.
Therefore, the Supreme Court affirmed the conviction of Janito M. Sedenio for violating the Anti-Violence Against Women and Their Children Act of 2004 (R.A. 9262).
Read the full Supreme Court Decision:
https://sc.judiciary.gov.ph/276927-janito-m-sedenio-vs-people-of-the-philippines/
