BAGUIO CITY, Philippines — The Supreme Court (SC) Third Division has acquitted a man of psychological violence under the Anti-Violence Against Women and Their Children Act (VAWC Law), clarifying that the emotional distress caused by a breakup or infidelity is not automatically a criminal offense. In a Decision promulgated on April 23, 2025, and penned by Associate Justice Alfredo Benjamin S. Caguioa, the Court emphasized that for a conviction under Section 5(i) of Republic Act No. 9262, the prosecution must prove beyond reasonable doubt that the accused acted with the specific criminal intent to cause mental or emotional anguish.
Infidelity Allegations and Emotional Anguish
The controversy involved Ronel Caridaoan, who was originally convicted by the Regional Trial Court of Baguio City for causing psychological abuse to his former live-in partner of eleven years, identified as AAA. The prosecution alleged that Caridaoan engaged in an affair with their car wash secretary, Michelle, while still living with AAA. They further claimed he “flaunted” the relationship by requiring AAA to share his time with the other woman and excluded AAA from their business profits while she was recovering from a serious heart condition, leading to severe depression and a worsening of her medical ailment.
The Court of Appeals had previously affirmed the conviction, ruling that the “mental infidelity” committed by Caridaoan was sufficient to establish a violation of the VAWC Law. However, Caridaoan elevated the case to the High Tribunal, arguing that he had formally ended his relationship with AAA before marrying Michelle and that any anguish AAA suffered was a normal, albeit painful, human experience resulting from a difficult breakup.
Proof of ‘Mens Rea’ is Mandatory
The Supreme Court reversed the conviction, ruling that the prosecution failed to establish the necessary element of mens rea, or a guilty mind. The Court explained that Section 5(i) of the VAWC Law is a mala in se offense, meaning the law punishes acts that are inherently wrong and require a mental element of ill will. The Court held that the prosecution must prove not just the woman’s suffering, but a direct causal link between that suffering and a deliberate, willful act by the accused intended specifically to cause her humiliation or mental anguish.
The SC found that the evidence actually contradicted the claim of criminal intent. The Court observed that despite leaving AAA for another woman, Caridaoan did not abandon her; instead, he provided substantial financial support for her open-heart surgery, allowed her to keep the full proceeds from the sale of a co-owned vehicle for her medical needs, and even hired a personal helper to assist in her recovery. The Court noted that these acts of good faith were incompatible with a “guilty state of mind” aimed at inflicting psychological harm.
Ruling on the ‘Peculiar Arrangement’ and Business Exclusion
The Court also dismissed the lower courts’ reliance on a supposed “arrangement” where Caridaoan split his time between both women. The SC pointed out that AAA herself admitted in her testimony that Caridaoan never forced this arrangement upon her and that she had voluntarily agreed to it in hopes that he would eventually realize his mistake. The Court stressed that a voluntary, non-coercive agreement, even if emotionally painful, cannot be the basis for a criminal conviction of psychological violence.
Furthermore, the Court found no evidence that Caridaoan maliciously excluded AAA from their business. It noted that AAA’s absence from the shop was based on her doctor’s advice to avoid stress following her surgery, and that Caridaoan continued to provide her with a share of the income and funds for her medication during this period. The Court held that a partner’s decision to manage a business while the other is medically incapacitated does not constitute psychological abuse.
The Distinction Between Heartbreak and Crime
The Supreme Court concluded that while the end of a long-term relationship is undoubtedly heartbreaking and causes significant emotional distress, such pain does not automatically translate into a crime. The ruling serves as a reminder that the gravamen of the VAWC Law is the intentional infliction of violence, not the inherent suffering found in intimate relationship conflicts. The Court emphasized that a person cannot be held criminally liable for the normal human experience of sadness or anxiety following a breakup unless there is proof of a willful and deliberate attempt to destroy the victim’s psychological well-being. Consequently, the SC annulled the previous judgments and ordered the immediate acquittal of Ronel Caridaoan.
