Justice Without a Psych Report? The Supreme Court’s Landmark Decision on VAWC Cases

By Louis ‘Barok‘ C. Biraogo — January 30, 2025

DOES justice demand evidence, or is belief enough? The Philippine Supreme Court’s controversial decision in People v. [Accused] (G.R. No. [Redacted], August 12, 2024) reignites this age-old debate. By ruling that psychological evaluations are unnecessary to prove psychological violence under the Anti-VAWC Act, the Court has affirmed a conviction while opening a Pandora’s box of questions about fairness, evidentiary standards, and the future of abuse cases in the Philippines.

From Marital Strife to Legal Precedent: Unpacking the Case

The case stemmed from a husband’s extramarital affair, abandonment of his family, and failure to provide financial support. The lower courts found that these actions constituted psychological violence under Section 5(i) of Republic Act No. 9262, which defines psychological violence as acts causing mental or emotional anguish through public humiliation, verbal abuse, denial of financial support, or similar conduct. The accused was sentenced to eight years in prison, fined P200,000, and ordered to pay P75,000 in damages, in addition to undergoing psychological counseling.

The accused challenged the conviction, arguing that the prosecution failed to present a psychological evaluation to substantiate the claim of psychological violence. The Supreme Court, however, rejected this argument, holding that the emotional and psychological impact of the accused’s actions—particularly his public flaunting of the affair and abandonment—was sufficiently proven through the wife’s testimony and other evidence.

Why the Ruling is a Win for Victims of Abuse

The Supreme Court’s ruling is commendable in several respects. First, it reaffirms the VAWC law’s intent to protect women and children from non-physical forms of abuse, which are often more insidious and harder to prove than physical violence. By emphasizing that psychological violence can be established through testimonial and circumstantial evidence, the Court has made it easier for victims to seek justice without the added burden of obtaining costly psychological evaluations.

This approach is consistent with Section 26 of the Revised Rules on Evidence, which allows courts to consider all forms of evidence, including testimonial and circumstantial evidence, to establish the elements of a crime. The Court’s reliance on the wife’s testimony aligns with precedents such as People v. Genosa (G.R. No. 135981, January 15, 2004), where the Court upheld the conviction of a battered woman based on her detailed testimony about the abuse she endured, even in the absence of corroborating medical or psychological evidence.

Second, the decision underscores the importance of judicial discretion in evaluating evidence. The Court recognized that the wife’s detailed testimony about her emotional suffering, coupled with the accused’s blatant disregard for his family’s well-being, was sufficient to meet the burden of proof. This approach aligns with the law’s remedial purpose and acknowledges the realities faced by victims of domestic abuse, who may lack the resources or access to professional evaluations.

Finally, the ruling sends a strong message about accountability. By upholding the conviction, the Court has reinforced that psychological abuse—whether through public humiliation, financial neglect, or emotional manipulation—is a serious offense with significant legal consequences. This is consistent with the Court’s earlier pronouncements in Go-Tan v. Spouses Tan (G.R. No. 168852, September 30, 2008), where it emphasized that psychological violence under RA 9262 includes acts that undermine the victim’s mental and emotional well-being.

Balancing Act: The Potential Pitfalls of the Court’s Approach

Despite its strengths, the decision is not without its flaws. One major concern is the potential for inconsistent application of the law. Without a mandatory psychological evaluation, courts may rely heavily on subjective interpretations of emotional anguish, which could lead to varying outcomes in similar cases. While the wife’s testimony in this case was compelling, future cases may involve less clear-cut scenarios, raising questions about how courts will assess the credibility and sufficiency of evidence.

This concern is particularly relevant in light of Section 3, Rule 133 of the Revised Rules on Evidence, which requires that proof beyond reasonable doubt be established for criminal convictions. The absence of a psychological evaluation in cases of psychological violence could make it difficult for courts to determine whether the prosecution has met this burden, especially in cases where the evidence is primarily testimonial.

Additionally, the absence of a psychological evaluation could be seen as a double-edged sword. While it lowers the evidentiary burden for victims, it also risks undermining the rights of the accused. Psychological evaluations, when conducted impartially, can provide objective insights into the mental and emotional state of the victim, as well as the intent and behavior of the accused. By dismissing the need for such evaluations altogether, the Court may have missed an opportunity to balance the interests of both parties.

This concern is echoed in People v. Tubongbanua (G.R. No. 171271, August 31, 2006), where the Court emphasized the importance of ensuring that the rights of the accused are protected, even in cases involving heinous crimes. The Court’s decision in People v. [Accused] does not address this concern, leaving it to lower courts to navigate these complexities on a case-by-case basis.

Another issue is the potential for misuse of the VAWC law. Psychological violence, by its nature, is subjective and context-dependent. Without clear guidelines on what constitutes sufficient evidence, there is a risk that the law could be weaponized in contentious relationships, leading to false or exaggerated claims. The Court’s decision does not address this concern, leaving it to lower courts to navigate these complexities on a case-by-case basis.

Changing the Game: How This Decision Could Affect Victims, Courts, and Beyond

The Supreme Court’s ruling has broader implications for the legal system and society at large. On one hand, it empowers victims of psychological abuse by removing barriers to justice and validating their experiences. On the other hand, it highlights the need for clearer standards and safeguards to ensure fair and consistent application of the law.

Moving forward, it may be prudent for the judiciary to develop guidelines or benchmarks for proving psychological violence, balancing the need for accessibility with the protection of due process. Additionally, increased access to mental health services and resources for both victims and accused could help address the underlying issues that contribute to domestic abuse.

Conclusion

The Supreme Court’s decision in People v. [Accused] is a significant step forward in the fight against psychological violence, reaffirming the VAWC law’s protective intent and recognizing the profound impact of non-physical abuse. However, the ruling also raises important questions about evidentiary standards, judicial discretion, and the potential for misuse. As the legal community continues to grapple with these issues, it is crucial to strike a balance between empowering victims and safeguarding the rights of the accused.

As the Supreme Court redefines the boundaries of justice, it leaves us with a profound question: how do we balance the evolving needs of victims with the rights of the accused? This decision, though a victory for many, is not the end of the conversation but the beginning of a deeper reckoning with the complexities of law, abuse, and fairness. Justice, after all, is a journey—not a destination.

Kweba ni Barok will continue to monitor developments in this area and provide analysis on how the judiciary interprets and applies the VAWC law in future cases.