12/04/2025
The Anti-Violence Against Women and Their Children Act of 2004 (RA No. 9262) aims to protect women and children from various forms of violence, including psychological abuse. Psychological violence under RA No. 9262 encompasses acts such as intimidation, harassment, stalking, public humiliation, repeated verbal abuse, and mental infidelity, which cause emotional anguish or mental suffering to the victim.
In the landmark case ###270257 vs. People of the Philippines and AAA (G.R. No. 270257, August 12, 2024), the Supreme Court clarified that a psychological evaluation is not indispensable for proving psychological violence under RA No. 9262. The Court emphasized that emotional anguish and mental suffering—key elements of psychological violence—can be established through the victim's testimony alone.
The accused in this case argued that a psychological report or expert testimony was necessary to substantiate claims of psychological violence. However, the Supreme Court ruled that such evidence is not required by law or jurisprudence. Instead, the victim's detailed testimony regarding her emotional ordeal suffices to prove the element of emotional anguish. For example, in this case, the victim recounted how the accused abandoned his family, engaged in an extramarital affair with a neighbor, flaunted this relationship publicly, and failed to provide financial support—all of which caused significant emotional distress.
The Court upheld the conviction of the accused for psychological violence and imposed penalties including imprisonment for up to eight years, fines amounting to PHP 275,000, and mandatory psychological counseling or psychiatric treatment. This decision reinforces the principle that personal testimony is sufficient to establish psychological violence under RA No. 9262 and eliminates barriers for victims who may struggle with accessing formal psychological evaluations due to trauma or other constraints.
