01/05/2026
SUPREME COURT ACQUITS BOYFRIEND IN VAWC CASE, SAYS COMPLAINT STEMMED FROM MERE LOVERS' QUARREL
The Supreme Court (SC) voting 3-2 has acquitted a man accused of psychological violence for allegedly threatening to kill his girlfriend if she refused to engage in s*xual in*******se, ruling that the prosecution failed to establish sufficient proof of mental and emotional anguish on the part of the complainant.
In a 21-page ruling penned by Associate Justice Henri Jean Paul Inting, the SC's Third Division reversed the ruling of the Court of Appeals (CA) finding the accused guilty of violation of Republic Act No. 9262, or the Anti-Violence Against Women and Their Children Act of 2004 (Anti-VAWC Act).
The case stemmed from a complaint filed by the girlfriend, who alleged that she received text messages from the accused demanding that they engage in s*xual in*******se, threatening to kill her if she refused.
The complainant alleged that she was emotionally abused by the accused throughout their almost four years of relationship. She narrated how the accused blackmailed her whenever she would not do his bidding. The accused would also threaten to post her n**e photos and their s*x video.
Unable to bear the burden any longer, the complainant sought the help of the police authorities as the accused demanded money from her in exchange for not uploading their s*x video. In response, the police officers organized an entrapment operation, but it did not materialize because the accused failed to meet up with her. The police conducted a second entrapment operation, during which the suspect was arrested after receiving Php2,000.
This prompted the complainant to file criminal cases for grave threats under Article 282 and violation of RA 9262 or the Anti-VAWC Law. The accused denied the allegations. He alleged that while he is working as an OFW in Taiwan, the complainant supposedly had another boyfriend. She apologized to him and promised not to cheat again.
The accused denied psychologically abusing the victim, claiming that the criminal complaints were filed out of vengeance. He alleged that the victim's parents sought revenge due to their disapproval of the relationship.
The Regional Trial Court (RTC) convicted the accused for violating Section 5(i) of the Anti-VAWC Act, highlighting that all the elements of psychological violence were proven by the prosecution. The Court of Appeals subsequently affirmed the said decision, paving the way for him to elevate the case before the Supreme Court.
In acquitting the accused, the SC ruled that the complainant failed to sufficiently prove that she suffered mental or emotional anguish. It emphasized that there is no sufficient proof that the accused acted purposefully and knowingly, with intent to alarm or cause substantial emotional or psychological distress to the victim.
The Court did not give great credence to the complainant’s testimony, noting that her actions appeared inconsistent with her claims. It pointed out that after allegedly receiving threatening text messages, she did not exhibit substantial distress, as shown by her willingness to ride the motorcycle with the accused.
"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."
Upon reviewing the text messages, the High Court found no clear intent on the part of the accused to cause mental anguish to the complainant. It noted that their exchanges showed the accused was still asking and making plans for a s*xual encounter, while also requesting a shirt as a gift.
"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.
It took into account the Instagram posts of the victim with the caption "Nagmahal, nasaktan, nagpakulong," alluding to the imprisonment of the accused. In another post, she posted a photograph of the accused in his jail cell with the statement, "Diba ang saya mo na. Lol," which, according to the court, is not a normal behavior of a victim of abuse.
"Thus, the foregoing circumstances all give rise to the conclusion that the case of AAA and ### 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.
