People v. XXX271087, G.R. No. 271087 (July 14, 2026)

A woman trapped in an abusive relationship cannot be expected to report every beating to the authorities or recount every traumatic memory in open court. Stigma, distrust of authorities, humiliation, and cultural pressures are some reasons that deter women from seeking help and push them to remain silent. Moreover, prolonged domestic abuse can cause victims to withdraw or dissociate leading to silence or even gaps in memory. This is how trauma operates. Courts must be careful not to demand an impossible standard of proof that is blind to the realities of abuse.¹

This Court resolves an appeal² from the Decision³ of the Court of Appeals affirming the Regional Trial Court’s Decision⁴ convicting accused-appellant XXX271087 of the crime of parricide.⁵

In a February 23, 2011 Information,⁶ XXX271087 was charged with parricide. The accusatory portion of the Information reads:

That on or about the 8ᵗʰ day of February 2011, in the City [redacted], Philippines, and within the jurisdiction of this Honorable Court, the said accused, did then and there willfully, unlawfully and feloniously, with intent to kill, shoot several times [AAA271087] with the use of 9mm pistol hitting him on the different parts of his body, the latter being his [sic] legitimate husband, thereby inflicting upon him fatal wounds which caused his immediate death.

CONTRARY TO LAW.⁷

On arraignment, XXX271087 pleaded not guilty to the charges against her.⁸ Thereafter, trial on the merits ensued.⁹

The prosecution presented the testimonies of three witnesses: BBB271087, victim AAA271087 sister-in-law; Police Officer II Sheryl Respicio (PO2 Respicio), the arresting officer; and CCC271087, AAA271087’s mother.¹⁰

According to the prosecution, the crime started from an argument between XXX271087 and AAA271087. On February 8, 2011, at 9:00 p.m., while BBB271087 was in her home, she heard XXX271087 screaming as she was coming out of their house. XXX271087 then went to BBB271087 and proceeded to tell her that AAA271087 was having an outburst. BBB271087 went to the spouses’ house and found AAA271087 with blood on his body. She asked AAA271087 what happened, but he did not respond. After making sure he was fine, BBB271087 returned to her house to tend to her store. A few moments later, she heard several gunshots coming from the spouses’ house. She rushed towards the house and knocked on the door. When the door opened, she saw XXX271087 with a gun in her hand, telling her “mas gugustuhin ko nalang makulong, te” (I would rather be imprisoned). She saw AAA271087’s body on the floor covered in blood.¹¹

Meanwhile, PO2 Respicio, the spouses’ neighbor, allegedly heard several gunshots while inside her home. Alerted, she went to investigate where the gunshots came from and was informed that XXX271087 shot AAA271087. Upon arriving at the spouses’ house, she found XXX271087 sitting on the sofa. XXX271087 told her that she accidentally shot AAA271087, saying “Ate nadisgrasya ko [AAA271087].” She then arrested XXX271087 and brought her to the [redacted] City Police Station for further investigation.¹²

CCC271087 testified on the veracity of AAA271087’s Certificate of Live Birth, the spouses’ Certificate of Marriage, and AAA271087’s Certificate of Death. AAA271087’s Certificate of Death showed he suffered multiple gunshot wounds in the head, right upper extremity, thorax, abdomen, and right and lower extremities.¹³

On the other hand, the defense presented XXX271087¹⁴ and interposed the defense of “battered wife syndrome.”¹⁵ The psychiatric report of Dr. Emery I. S. Layugan (Dr. Layugan), a government psychiatrist,¹⁶ and Dr. Ethel Maureen Pagaddu (Dr. Pagaddu), the doctor who assisted Dr. Layugan, was likewise presented.¹⁷

XXX271087 testified that she and AAA271087 had been married for 11 years and had three sons. The relationship soured when AAA271087 was assigned in [redacted]. She noticed that he started coming home at around 1:00 to 2:00 a.m. and heard rumors that he was seeing another woman.¹⁸

In one instance, XXX271087 followed AAA271087 and saw him board a female passenger on his motorcycle. At another time, she received an anonymous phone call informing her that AAA271087 was at a particular hotel, where she caught him in bed with another woman. AAA271087 restrained XXX271087 as the woman physically attacked her. Since this incident, AAA271087 became violent towards XXX271087. He would arrive home drunk and beat her with his bare hands for about four times a week.¹⁹

On a separate occasion, AAA271087 had choked XXX271087 and pointed a firearm at her when she told him she wanted to leave him. When she attempted to ask help from her neighbors, he threatened to kill her. Out of fear, XXX271087 did not file a complaint against AAA271087.²⁰

On February 8, 2011, at 6:00 p.m., XXX271087 found AAA271087 shouting at their children. When he noticed her, AAA271087 started throwing objects around. He then picked up their two-year-old son and threw him on a chair. In response, XXX271087 picked up a ladle and struck him on the head. She then ran outside to ask help from BBB271087, who advised her to resolve the problem by talking to AAA271087. However, when she tried to talk to him, AAA271087 hurled obscenities at her.²¹

At 8:00 p.m., XXX271087 started packing her clothes to leave the house. AAA271087 saw this and threatened her that they would not get out of the house alive. He then started beating her and slammed her head against a wall. This caused her vision to dim. XXX271087 claims that her memory went blank and when she regained consciousness, she was already at the police station.²²

On January 21, 2020, the Regional Trial Court rendered its Decision²³ convicting XXX271087 of parricide:²⁴

WHEREFORE, judgment is hereby rendered finding accused [XXX271087] guilty beyond reasonable doubt of the crime of Parricide and is hereby sentenced to suffer the penalty of reclusion perpetua and to pay the heirs of the victim, [AAA271087] the amounts of P75,000.00 as civil indemnity, P75,000.00 as moral damages, P30,000.00 as exemplary damages, and P25,000.00 as temperate damages. In addition, all the monetary awards shall earn an interest at the legal rate of 6% per annum from the date of finality of this decision until fully paid.

SO ORDERED.²⁵

XXX271087 appealed the Regional Trial Court’s Decision before the Court of Appeals.²⁶

In its assailed August 9, 2023 Decision,²⁷ the Court of Appeals affirmed, with modifications, the Regional Trial Court’s Decision.²⁸

The Court of Appeals found that the defense failed to discharge its burden in proving that XXX271087 acted in self-defense arising from battered woman syndrome.²⁹ Both the Regional Trial Court and Court of Appeals found that XXX271087 was unable to provide any evidence demonstrating the concurrence of the three phases of the cycle of violence or supporting her claim that she went through multiple instances of abuse.³⁰

The dispositive portion of the Court of Appeals’ Decision reads:

WHEREFORE, premises considered, the present appeal is DENIED. The assailed Decision dated 21 January 2020 rendered by the Regional Trial Court of [redacted], [redacted] Judicial Region, Branch [redacted] in Criminal Case No. 19-7211 convicting accused-appellant [XXX271087] of parricide, and ordering her to pay the heirs of [AAA271087], civil indemnity and moral damages in the amount of Php75,000.00 each, is hereby AFFIRMED WITH MODIFICATIONS in that in addition to all the damages awarded, the amount of exemplary damages is increased to Php75,000.00 and temperate damages is increased to Php50,000.00. The total amount of damages shall earn a legal interest of six percent (6%) per annum from the date of finality of this Decision until full payment thereof.

SO ORDERED.³¹ (Emphasis in the original)

Aggrieved, XXX271087 filed her Notice of Appeal,³² which was given due course by the Court of Appeals.³³ The case records were thus elevated to this Court.

On August 27, 2024, this Court issued a Resolution³⁴ notifying the parties that they may file their respective supplemental briefs. The confinement of XXX271087 at the Correctional Institution for Women in Mandaluyong City since October 21, 2022 has also been confirmed.³⁵

Both the Office of the Solicitor General, on behalf of the People of the Philippines,³⁶ and XXX271087, through her counsel from the Public Attorney’s Office,³⁷ manifested that they would no longer file their supplemental briefs and would instead be adopting the briefs filed before the Court of Appeals.

In her Brief,³⁸ XXX271087 argues that the trial court erred in convicting her since she was afflicted with the battered woman syndrome, a lawful defense in the crime of parricide.³⁹ She presents the psychiatric evaluation report by government physician Dr. Layugan which she deems a public document due to being conducted pursuant to an order from the trial court and therefore, does not require authentication to be admitted as evidence.⁴⁰

She posits that the psychiatric report shows how AAA271087 abused her, satisfying the requisites of the battered woman syndrome defense. According to XXX271087, she went through the cycle of violence twice. She claims that the second instance of acute battering happened when AAA271087 slammed her head against the wall, constituting unlawful aggression on his part. This propelled her to act not only in self-defense, but in defense of her children.⁴¹

Finally, she argues that the trial court misinterpreted facts, evidence, and jurisprudence when it ruled that XXX271087 is guilty of parricide. She argues that she had proven, through the psychiatric report, the abuse she had suffered under AAA271087’s hands. She maintains that her account should have been given greater credence.⁴²

On the other hand, in its Appellee’s Brief,⁴³ the People, through the Office of the Solicitor General, argues that XXX271087’s guilt was proven beyond reasonable doubt.⁴⁴

It posits that there is no evidence establishing XXX271087’s battered woman syndrome and maintains that there is doubt as to whether AAA271087 completed at least two cycles of violence. Even assuming that Dr. Layugan’s psychiatric report was admissible, it maintains that there is no collateral evidence establishing XXX271087’s theory of abuse.⁴⁵ Finally, it maintains that all the elements of the crime of parricide have been established by the prosecution.⁴⁶

The sole issue for this Court’s resolution is whether accused-appellant XXX271087 is guilty beyond reasonable doubt of parricide. Subsumed in this issue is whether the battered woman syndrome defense must be appreciated.

The appeal is with merit.

I

Accused-appellant was convicted of parricide under Article 246 of the Revised Penal Code, which provides:

Article 246. Parricide. — Any person who shall kill his father, mother, or child, whether legitimate or illegitimate, or any of his ascendants, or descendants, or his spouse, shall be guilty of parricide and shall be punished by the penalty of reclusion perpetua to death.

Parricide is committed when: (1) a person is killed; (2) the deceased is killed by the accused; (3) the deceased is the father, mother, or child, whether legitimate or illegitimate, or any other legitimate ascendant or descendant, or the legitimate spouse of the accused.⁴⁷

In this appeal, accused-appellant admits that she indeed shot her husband.⁴⁸ The spousal relationship between the accused-appellant and the victim is undisputed, there being a valid marriage certificate,⁴⁹ as well as admission from accused-appellant herself.⁵⁰ Similarly, accused-appellant’s participation in AAA271087’s death has been clearly established by the testimonies of the prosecution witnesses.⁵¹ Accused-appellant admits, in her testimony and brief before the Court of Appeals, that the emotional and physical abuse she suffered led her to end his life by shooting him with his own gun.⁵² Her defense is that she suffers from the battered woman syndrome.⁵³

Battered woman syndrome was recognized by this Court in the landmark case of People v. Genosa⁵⁴ and was defined as a woman “who is repeatedly subjected to any forceful physical or psychological behavior by a man in order to coerce her to do something he wants her to do without concern for her rights.”⁵⁵ It recognized the battered woman syndrome as a legitimate psychological condition arising from domestic abuse and characterized by the cycle of violence which has three phases: (1) the tension-building phase; (2) the acute battering incident; and (3) the nonviolent phase.⁵⁶ To be classified as a battered woman, the couple must go through the battering cycle at least twice.⁵⁷

The tension-building phase is where tension and conflict begin to build in the relationship. The abuser becomes increasingly irritable, angry, and unpredictable. The woman may try to placate, avoid conflict, or stay out of the abuser’s way to prevent an escalation. The woman may classify the abuse experienced here as only minor occurrences, leading to the worsening of the abuse.⁵⁸

The acute battering incident is characterized by brutality and in the worst cases, death. This is when the tension reaches its breaking point, and the abuser releases the built-up tension through a violent, abusive outburst. This can include physical, sexual, and emotional abuse or other forms of aggression.⁵⁹

The final phase involves the reconciliation phase. The abuser may apologize, express remorse, or promise never to hurt the victim again. They may shower the victim with affection, gifts, or attention to make up for the abuse. The victim, wanting to believe in the abuser’s promises, may stay in the relationship.⁶⁰

Genosa ruled that a claim of battered woman syndrome must be well-established and supported by firm evidence. To successfully invoke this defense, there are three requirements that must be met:

First, each of the phases of the cycle of violence must be proven to have characterized at least two battering episodes between the appellant and her intimate partner. Second, the final acute battering episode preceding the killing of the batterer must have produced in the battered person’s mind an actual fear of an imminent harm from her batterer and an honest belief that she needed to use force in order to save her life. Third, at the time of the killing, the batterer must have posed probable — not necessarily immediate and actual — grave harm to the accused, based on the history of violence perpetrated by the former against the latter. Taken altogether, these circumstances could satisfy the requisites of self-defense.⁶¹

The court recognized that prolonged battering could lead to learned helplessness which is described as “the battered woman’s perceptions that she is helpless to stop the abuse and explains why she does not leave her abuser.”⁶²

This creates a perception of imminent danger a battered woman may experience even in the absence of an active attack. However, for it to be a defense there must be clear evidence proving both the (1) the history of abuse⁶³ and (2) the psychological effect of the battery on the appellant.⁶⁴ Ultimately, the Court found that the appellant in Genosa failed to prove the existence of the syndrome.⁶⁵ Furthermore, it held that unlawful aggression, the most essential element for self-defense, was lacking since there was sufficient interval between the unlawful aggression of Ben and Marivic’s fatal attack upon him. However, the Court considered the circumstances as mitigating, thereby reducing her penalty from death to prision mayor in its minimum period to reclusion temporal in its medium period.⁶⁶

Prior jurisprudence set a high threshold for those invoking self-defense based on battered woman syndrome. Thus, to expand protections for victims of domestic abuse, Republic Act No. 9262, also known as the Anti-Violence Against Women and Their Children Act of 2004 was promulgated. Under the law, battered woman syndrome is codified and defined as, “a scientifically defined pattern of psychological and behavioral symptoms found in women living in battering relationships as a result of cumulative abuse.”⁶⁷ While traditional self-defense requires the concurrence of three elements: (i) unlawful aggression; (ii) reasonable necessity of the means employed to prevent or repel it; and (iii) lack of sufficient provocation on the part of the person defending herself;⁶⁸ Section 26 of Republic Act No. 9262 expressly provides that a victim found suffering from battered woman syndrome shall not incur criminal and civil liability, even in the absence of any of the elements required. Section 26 reads:

SECTION 26. Battered Woman Syndrome as a Defense. — Victim-survivors who are found by the courts to be suffering from battered woman syndrome do not incur any criminal and civil liability notwithstanding the absence of any of the elements for justifying circumstances of self-defense under the Revised Penal Code.

In the determination of the state of mind of the woman who was suffering from battered woman syndrome at the time of the commission of the crime, the courts shall be assisted by expert psychiatrists/psychologists.

The legislative intent is unmistakable. Congress recognized that the lived realities of battered women do not always conform to the traditional paradigm of combat contemplated in the self-defense doctrine. Domestic violence occurs through a series of physical, sexual, and psychological harm, or economic abuse⁶⁹ that result in a pattern of psychological and behavioral symptoms. The sustained intimidation, coercion, and domination used on the woman instills a sense of fear and psychological entrapment.⁷⁰ Consequently, Section 26 does not demand that the battered woman wait for a fatal attack before acting in preservation of life. To insist otherwise is to ignore the cyclical nature of domestic violence that the law itself was enacted to address.

II

Accused-appellant successfully satisfied the three phases required to establish battered woman syndrome. Records demonstrate that accused was not merely a spouse who had a quarrel with her husband. She was a woman repeatedly diminished by her partner through violence and intimidation.

The first cycle began its tension-building phase when AAA271087 became emotionally distant after his reassignment. He regularly came home at around two in the morning and rumors of infidelity started circulating. Accused-appellant started feeling anxious, suspicious, and distressed. Her husband’s cold demeanor created an atmosphere of instability in the marriage. The violence escalated into the acute battering stage when on September 16, 2010,⁷¹ she discovered AAA271087 in a hotel room with another woman and, instead of receiving remorse, was restrained while she was physically assaulted. She sustained serious injuries which required her to seek hospital treatment. Accused-appellant obtained a medical certificate⁷² signed by Dr. Gay Ladylyn Azman on February 2, 2012 showing that she was brought to the hospital with the following diagnosis:

Hematoma, frontal area, midline
Hematoma, mandibular area, left
Lacerated wound, palmar aspect, hand, left.⁷³

While the accused-appellant did not mention that she received an apology from her husband, the fact that the marriage and cohabitation continued after the hotel incident indicates a reconciliation period between husband and wife. The “contrition or honeymoon phase” need not involve grand gestures of remorse but may sometimes consist of merely a temporary calm between the couple.

Thereafter, the abuse continued behind closed doors. This is where the second cycle of the tension building phase begins. AAA271087 repeatedly came home late and physically abused accused-appellant for no apparent reason.⁷⁴ The abuse persisted for over two years, yet accused-appellant remained with her husband. She did not seek police assistance because she feared retaliation and distrusted law enforcement due to her husband’s position as a police officer. Her neighbors consisted of her sister-in-law and a colleague of her husband which heightened her isolation and prolonged her helplessness.

The final violent confrontation in February 2011 constitutes another acute battering episode. AAA271087 shouted at their children and violently threw their youngest child onto a chair. When accused-appellant intervened by striking him with a ladle, she was assaulted. She then ran outside to ask help from her sister-in-law BBB271087. Afterwards, accused-appellant returned to the house and remained there, completing another cycle.

Later that night, accused-appellant started packing her clothes to leave the house. AAA271087 saw this, threatened her, saying she would not get out of the house alive. He then started beating her and slammed her head against a wall causing her vision to blur. Afterwards, accused-appellant claims that her memory went blank and when she regained consciousness, she was already at the police station.⁷⁵

In the present case, the defense successfully established that the accused-appellant underwent at least two full cycles of battered woman syndrome. Given the duration of the abuse and the severity of the assaults she had sustained, this Court finds that the violence perpetrated by AAA271087 against accused-appellant were not isolated incidents but a systemic pattern. This fundamentally altered accused-appellant’s state of mind and caused her to have learned helplessness that led her to believe that only killing her husband would free her.

To validate this psychological state, the defense secured the psychiatric report of Dr. Layugan, a government psychiatrist,⁷⁶ who reported accused-appellant’s narration of the circumstances of her marriage to AAA271087⁷⁷ and included a finding she suffered from major depressive disorder.⁷⁸ The defense also brought in Dr. Pagaddu, who testified:

Q: And this case involved the person of [XXX271087], do you know the person of [XXX271087]?
A: Yes, sir.

Q: How did you come to know her?
A: She was brought to the Medical Center dated September 12, 2018, with the court order for her to undergo psychiatric examination, sir.

Q: How many times did the accused report to your office?
A: Three (3) times, sir.

Q: On those three (3) times that the accused reported to your office, what did … and what were your activities, if any?
A: She was subjected for several interview, she reported, she was also subjected for battery of psychiatric test, sir.

Q: You mentioned of battery of psychiatric test, what do you mean?
A: She was subjected for psychiatric examination, and it is reflected under Head Psychiatric Results.

Q: And on these meetings or sessions with the accused, what did you find out?
A: The patient was found out to be suffering from Major depressive [dis]order.

Q: As x x x a doctor for behavioral medicine, what do you think is the source of that disorder?
A: Of course the formation or symptoms for multiple and biological going on inside the body of the person like decrease in the level of cerotomie, it could also be secondary to psychiatric factors like exposure to violence, abuse and several factors which includes relationship with people that the patient comes to deal with, sir.

Q: So considering that you alleged that the accused is suffering from major depression disorder, how did you come up with that result?
A: It is the result of the evaluation that was conducted concerning the kind of relationship that she had with [the] late husband considering that the symptoms of depression started when her relationship with her late husband became stormy.

Q: What do you mean stormy?
A: In the sense that physical, emotional and psychological abuse inflicted by the late husband to the patient.

Q: And if a person is suffering from this disorder, what may be the consequence?
A: It may last for years and or lifetime, the patient experiences hopelessness, worthlessness of the chaotic relationship that she was decreasing self-esteem, things that has responded to save the relationship or responsibility to transform the behavior of the abuser, [her] late husband.

Q: Madam Witness in this case, the accused [XXX271087] is charged with parricide and at the time of the alleged incident time, do you think was ft state of mind or mental condition of the accused.
A: Based on the narration of the patient, there was this thing if the husband survived[,] she and her children will die, it is a self defense to save, who was the very reason why she remained with the chaotic relationship that she had with the late husband.⁷⁹

As instructed in Genosa and codified in Section 26 of the Anti-Violence Against Women and Their Children Act, the Court can find assistance from expert psychologists or psychiatrists to determine the state of mind of the woman that may be suffering from battered woman syndrome. The testimony of the expert serves as the bridge that explains why the victim, or, in this case, accused-appellant, acted the way she did.

In testifying that accused-appellant’s Major Depressive Disorder was a direct consequence of the physical, emotional, and psychological abuse she endured, Dr. Pagaddu showed that her actions were moved by self-preservation and desperation. After conducting multiple clinical interviews and a battery of psychiatric tests, the expert’s findings established a clear causal link between the husband’s “stormy” aggression and accused-appellant’s compromised mental state. This demonstrates that accused-appellant’s act was the breaking point of a victim trapped in a medically recognized cycle of violence. To her mind, shooting her husband was the only way she could finally bring an end to the cycle.

III

The Court of Appeals erred when it affirmed the lower court’s decision to convict accused-appellant. It held that the psychological report and accused-appellant’s own declarations were insufficient to support her claim of battered woman syndrome. The Court of Appeals further noted that there was a lack of corroborating testimonies from relatives, neighbors, or even her own children and no medical or police reports to present any pattern of physical abuse.

The Court of Appeals’ high evidentiary requirement is misplaced.

Studies have shown that women in abusive relationships are unwilling to report violent instances due to a numerous of reasons including social stigma, lack of trust on authorities, humiliation, and cultural structures.⁸⁰ Accordingly, one cannot expect those trapped in the cycle of violence would be able to report every beating or recount every traumatic memory. Women subjected to prolonged domestic abuse may remain silent and forget details because the mind itself withdraws or disassociates to shield the victim from unbearable pain.⁸¹ Courts must be careful not to demand an impossible standard of proof detached from the realities of abuse. This becomes even more compelling where, as here, the alleged abuser occupied a position of authority as a police officer. The accused’s fear of reporting abuse to law enforcement cannot be dismissed as unreasonable.

This is consistent with the Philippines’ obligations under the Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW), which recognizes gender-based violence as a form of discrimination and obligates courts and public institutions to ensure the effective protection of women against such acts.⁸² CEDAW General Recommendation No. 35 further instructs States to ensure that evidentiary rules are not influenced by gender stereotypes or unrealistic expectations regarding victim behavior.⁸³ It likewise notes that courts must abandon antiquated “application of preconceived and stereotypical notions of what constitutes gender-based violence against women, what women’s responses to such violence should be and the standard of proof required to substantiate” it.⁸⁴

Accordingly, the Court gives weight to the findings of the court-appointed psychologist who diagnosed the accused with major depressive disorder and who found that the abuse experienced by the accused-appellant in the hands of her husband as what moved her to inflict the fatal shots. While the expert may not have elicited a detailed catalogue of every prior assault, such limitation does not erase the broader truth reflected by the record.

The absence of exhaustive corroboration for every prior incident does not negate the existence of battered woman syndrome where the totality of the evidence, the documented injuries, the testimony regarding repeated abuse, the psychological findings, and the violent events immediately preceding the shooting, sufficiently establish a pattern of battering and coercive control.

Courts must interpret Republic Act No. 9262 with an awareness of the lived realities that compelled its enactment. The law was intended to protect women trapped in cycles of violence that conventional criminal doctrines did not consider. To deny the accused the protection of Section 26 simply because her abuse was not perfectly documented would be to impose upon battered women a burden the law itself never intended.

The Court therefore finds that the accused was suffering from battered woman syndrome at the time of the incident and is consequently exempt from criminal and civil liability pursuant to Section 26 of Republic Act No. 9262.

ACCORDINGLY, the appeal is GRANTED. The August 9, 2023 Decision of the Court of Appeals in CA-G.R. CR-HC No. 14921 is REVERSED AND SET ASIDE. Accused-appellant XXX271087 is ACQUITTED.

She is ordered immediately RELEASED from detention, unless she is confined for some other lawful cause.

Let a copy of this Decision be furnished to the Director General of the Bureau of Corrections for immediate implementation. The Director General of the Bureau of Corrections is directed to report the action he has taken to this Court within five days from receipt of this Decision.

Let entry of final judgment be issued immediately.

SO ORDERED.

Footnotes

¹ Vito Zepinic, Battered Women Syndrome: A Headache for Medicine and Law, 12 PSYCHOLOGY, 843, 848, 853 (2021), available at https://doi.org/10.4236/psych.2021.126052 (last accessed June 30, 2026).

² Rollo, pp. 3–5.

³ Id. at 10–32. The August 9, 2023 Decision in CA-G.R. CR-HC No. 14921 was penned by Associate Justice Ramon M. Bato, Jr. and concurred in by Associate Justices Ronaldo Roberto B. Martin and Alfonso C. Ruiz II of the Fourth Division of the Court of Appeals, Manila.

⁴ Id. at 35–43. The January 21, 2020 Decision in Crim. Case No. 19-7211 was penned by Judge Raul V. Babaran of Branch [redacted], Regional Trial Court, [redacted].

⁵ Id. at 30–31.

⁶ Id. at 10–11.

⁷ Id.

⁸ Id. at 10.

⁹ Id. at 11.

¹⁰ Id.

¹¹ Id.

¹² Id.

¹³ Id. at 12.

¹⁴ Id.

¹⁵ CA rollo, p. 60. Also referred to as “battered woman syndrome” in other parts of the rollo.

¹⁶ Rollo, p. 14.

¹⁷ Id. at 11.

¹⁸ Id. at 12.

¹⁹ Id.

²⁰ Id.

²¹ Id.

²² Id.

²³ Id. at 35–43.

²⁴ Id. at 43.

²⁵ Id.

²⁶ Id. at 12.

²⁷ Id. at 10–32.

²⁸ Id. at 31.

²⁹ Id. at 16.

³⁰ Id. at 22.

³¹ Id. at 31.

³² Id. at 3–5.

³³ Id. at 8.

³⁴ Id. at 51.

³⁵ Id.

³⁶ Id. at 46–47.

³⁷ Id. at 53–54.

³⁸ CA rollo, pp. 27–55.

³⁹ Id. at 35.

⁴⁰ Id. at 36–39.

⁴¹ Rollo, p. 14.

⁴² CA rollo, p. 53.

⁴³ Id. at 72–111.

⁴⁴ Id. at 78.

⁴⁵ Rollo, p. 14.

⁴⁶ CA rollo, p. 108.

⁴⁷ People v. Tibon, 636 Phil. 521, 530 (2010) [Per J. Velasco Jr., First Division].

⁴⁸ Rollo, p. 37.

⁴⁹ Id. at 35.

⁵⁰ Id. at 37.

⁵¹ Id. at 36.

⁵² Id. at 37.

⁵³ Id.

⁵⁴ 464 Phil. 680 (2004) [Per J. Panganiban, En Banc].

⁵⁵ Id. at 714–715.

⁵⁶ Id. at 715.

⁵⁷ Id. at 714–715.

⁵⁸ Id. at 715–716. See also J. Sangeetha, S. Mohan, A. Hariharasudan, A., Nishad Nawaz, Strategic analysis of intimate partner violence (IPV) and cycle of violence in the autobiographical text- When I Hit You, 8 HELIYON: A CELL PRESS JOURNAL 1, 4–5 (2022), available at https://pmc.ncbi.nlm.nih.gov/articles/PMC9233205 (last accessed on June 1, 2026).

⁵⁹ J. Sangeetha, S. Mohan, A. Hariharasudan, A., Nishad Nawaz, Strategic analysis of intimate partner violence (IPV) and cycle of violence in the autobiographical text- When I Hit You, 8 HELIYON: A CELL PRESS JOURNAL 1, 5 (2022), available at https://pmc.ncbi.nlm.nih.gov/articles/PMC9233205 (last accessed on June 1, 2026).

⁶⁰ Id. See also People v. Genosa, 464 Phil. 680, 716–717 (2004) [Per J. Panganiban, En Banc].

⁶¹ People v. Genosa, 464 Phil. 680, 748 (2004) [Per J. Panganiban, En Banc].

⁶² L. Walker, et al., Beyond the Juror’s Ken: Battered Women, 1 VT. L. REV. 1, 6 (1982).

⁶³ People v. Genosa, 464 Phil. 680, 717 (2004) [Per J. Panganiban, En Banc].

⁶⁴ Id. at 731.

⁶⁵ Id. at 735.

⁶⁶ Id. at 746–747.

⁶⁷ Republic Act No. 9262, sec. 3(c).

⁶⁸ REVISED PENAL CODE (1930), art. 11.

⁶⁹ Republic Act No. 9262 (2004), sec. 3(a)(A)(B)(C)(D), Anti-Violence Against Women and Their Children Act of 2004.

⁷⁰ United Nations, What is Domestic Abuse?, available at https://www.un.org/en/coronavirus/what-is-domestic-abuse (last accessed on June 1, 2026).

⁷¹ Rollo, pp. 18–20.

⁷² Id. at 20.

⁷³ Id.

⁷⁴ Id. at 12.

⁷⁵ Id.

⁷⁶ Id. at 14.

⁷⁷ Id. at 21.

⁷⁸ Id. at 22.

⁷⁹ Id. at 23–24.

⁸⁰ Vito Zepinic, Battered Women Syndrome: A Headache for Medicine and Law, 12 PSYCHOLOGY, 843, 848, 853 (2021), available at https://doi.org/10.4236/psych.2021.126052 (last accessed June 30, 2026).

⁸¹ Id.

⁸² Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW): September 3, 1981, United Nations General Assembly Resolution 34/180.

⁸³ UN Committee on the Elimination of Discrimination against Women, Gender-Based Violence Against Women, Updating General Recommendation No. 19 (1992), 10, CEDAW General Recommendation 35, (July 26, 2017).

⁸⁴ Id. at 11.

Case Digest

People v. XXX271087
G.R. No. 271087, July 14, 2026
[Per SAJ Leonen, Second Division]

Syllabus: Criminal Law; Parricide (Article 246, Revised Penal Code); Battered Woman Syndrome as a Defense (Section 26, Republic Act No. 9262); Cycle of Violence; Self-Defense; Exempting Circumstances; Evidence; Expert Testimony; Quantum of Corroboration in Domestic Abuse Cases

Doctrines

1. Parricide is committed when: (1) a person is killed; (2) the deceased is killed by the accused; and (3) the deceased is the father, mother, or child, whether legitimate or illegitimate, or any other legitimate ascendant or descendant, or the legitimate spouse of the accused.
2. Battered woman syndrome is “a scientifically defined pattern of psychological and behavioral symptoms found in women living in battering relationships as a result of cumulative abuse.” It is characterized by a cycle of violence with three phases: (1) the tension-building phase; (2) the acute battering incident; and (3) the nonviolent or reconciliation phase. To be classified as a battered woman, the couple must go through the battering cycle at least twice.
3. Under People v. Genosa, the defense requires that:
   1. each phase of the cycle of violence characterized at least two battering episodes;
   2. the final acute battering episode before the killing produced in the woman’s mind an actual fear of imminent harm and an honest belief that she needed to use force to save her life; and
   3. at the time of the killing, the batterer posed probable, not necessarily immediate and actual, grave harm to the accused, based on his history of violence.
4. Under Section 26 of Republic Act No. 9262, a woman found suffering from battered woman syndrome incurs no criminal and civil liability, even if the elements of self-defense under the Revised Penal Code are absent. She need not wait for a fatal attack before acting to preserve her life.
5. The reconciliation or “honeymoon” phase need not involve grand gestures of remorse. It may consist merely of a temporary calm between the couple, such as the continuation of the marriage and cohabitation after an acute battering incident.
6. In determining the woman’s state of mind, courts are assisted by expert psychiatrists or psychologists. Expert testimony serves as the bridge that explains why the woman acted as she did.
7. Battered woman syndrome does not require exhaustive corroboration of every prior incident of abuse. The totality of the evidence may establish a pattern of battering and coercive control: documented injuries, testimony on repeated abuse, psychological findings, and the violent events immediately before the killing. Courts must not demand an impossible standard of proof that ignores the realities of abuse.

Facts:

XXX271087 was charged with parricide for shooting her husband, AAA271087, a police officer, several times with a 9mm pistol on February 8, 2011, causing his death.

The prosecution presented three witnesses:

• BBB271087, the victim’s sister-in-law. She testified that XXX271087 came to her that evening saying that AAA271087 was having an outburst. She found AAA271087 with blood on his body. She returned to her store, then heard gunshots. When the door opened, XXX271087 was holding a gun and said, “mas gugustuhin ko nalang makulong, te” (I would rather be imprisoned).
• PO2 Sheryl Respicio, a neighbor. She found XXX271087 on the sofa. XXX271087 told her she had accidentally shot her husband, and PO2 Respicio arrested her.
• CCC271087, the victim’s mother. She identified the marriage certificate and the death certificate, which showed multiple gunshot wounds.

XXX271087 invoked battered woman syndrome. She testified that the marriage soured after her husband’s reassignment. He came home late, and there were rumors of another woman. She once caught him in a hotel with a woman who attacked her while he restrained her. After that, he often came home drunk and beat her about four times a week. Once, he choked her and pointed a gun at her when she said she wanted to leave. She did not report him because she was afraid.

She described the events of February 8, 2011. At 6:00 p.m., her husband shouted at their children and threw their two-year-old son onto a chair. She hit him with a ladle and ran to BBB271087 for help, but was told to talk to him. At 8:00 p.m., she began packing to leave. He threatened that they would not get out of the house alive, beat her, and slammed her head against a wall. Her vision dimmed and her memory went blank. She next remembered being at the police station.

The defense presented the psychiatric report of Dr. Emery I. S. Layugan, a government psychiatrist, and the testimony of Dr. Ethel Maureen Pagaddu. They found that XXX271087 suffered from major depressive disorder caused by her husband’s physical, emotional, and psychological abuse. A medical certificate also documented hematomas and a lacerated wound from the hotel incident.

The Regional Trial Court (RTC) convicted her of parricide and sentenced her to reclusion perpetua. The Court of Appeals (CA) affirmed and increased the damages. It held that she failed to prove the three phases of the cycle of violence or repeated abuse, noting that no relatives, neighbors, children, medical reports, or police reports corroborated her claims.

Issues:

1. Is XXX271087 guilty beyond reasonable doubt of parricide?
2. Should the defense of battered woman syndrome be appreciated in her favor?

Ruling:

1. Is XXX271087 guilty beyond reasonable doubt of parricide? — No. Although all the elements of parricide are present, she is exempt from criminal and civil liability under Section 26 of Republic Act No. 9262.

Accused-appellant was convicted of parricide under Article 246 of the Revised Penal Code, which provides:

Article 246. Parricide. — Any person who shall kill his father, mother, or child, whether legitimate or illegitimate, or any of his ascendants, or descendants, or his spouse, shall be guilty of parricide and shall be punished by the penalty of reclusion perpetua to death.

Parricide is committed when: (1) a person is killed; (2) the deceased is killed by the accused; (3) the deceased is the father, mother, or child, whether legitimate or illegitimate, or any other legitimate ascendant or descendant, or the legitimate spouse of the accused.

In this appeal, accused-appellant admits that she indeed shot her husband. The spousal relationship between the accused-appellant and the victim is undisputed, there being a valid marriage certificate, as well as admission from accused-appellant herself. Similarly, accused-appellant’s participation in AAA271087’s death has been clearly established by the testimonies of the prosecution witnesses. x x x Her defense is that she suffers from the battered woman syndrome.

x x x

The Court therefore finds that the accused was suffering from battered woman syndrome at the time of the incident and is consequently exempt from criminal and civil liability pursuant to Section 26 of Republic Act No. 9262.

2. Should the defense of battered woman syndrome be appreciated in her favor? — Yes.

(a) Legal framework

Battered woman syndrome was recognized by this Court in the landmark case of People v. Genosa and was defined as a woman “who is repeatedly subjected to any forceful physical or psychological behavior by a man in order to coerce her to do something he wants her to do without concern for her rights.” It recognized the battered woman syndrome as a legitimate psychological condition arising from domestic abuse and characterized by the cycle of violence which has three phases: (1) the tension-building phase; (2) the acute battering incident; and (3) the nonviolent phase. To be classified as a battered woman, the couple must go through the battering cycle at least twice.

x x x

Genosa ruled that a claim of battered woman syndrome must be well-established and supported by firm evidence. To successfully invoke this defense, there are three requirements that must be met:

First, each of the phases of the cycle of violence must be proven to have characterized at least two battering episodes between the appellant and her intimate partner. Second, the final acute battering episode preceding the killing of the batterer must have produced in the battered person’s mind an actual fear of an imminent harm from her batterer and an honest belief that she needed to use force in order to save her life. Third, at the time of the killing, the batterer must have posed probable — not necessarily immediate and actual — grave harm to the accused, based on the history of violence perpetrated by the former against the latter. Taken altogether, these circumstances could satisfy the requisites of self-defense.

x x x

Prior jurisprudence set a high threshold for those invoking self-defense based on battered woman syndrome. Thus, to expand protections for victims of domestic abuse, Republic Act No. 9262, also known as the Anti-Violence Against Women and Their Children Act of 2004 was promulgated. Under the law, battered woman syndrome is codified and defined as, “a scientifically defined pattern of psychological and behavioral symptoms found in women living in battering relationships as a result of cumulative abuse.” While traditional self-defense requires the concurrence of three elements: (i) unlawful aggression; (ii) reasonable necessity of the means employed to prevent or repel it; and (iii) lack of sufficient provocation on the part of the person defending herself; Section 26 of Republic Act No. 9262 expressly provides that a victim found suffering from battered woman syndrome shall not incur criminal and civil liability, even in the absence of any of the elements required. Section 26 reads:

SECTION 26. Battered Woman Syndrome as a Defense. — Victim-survivors who are found by the courts to be suffering from battered woman syndrome do not incur any criminal and civil liability notwithstanding the absence of any of the elements for justifying circumstances of self-defense under the Revised Penal Code.

In the determination of the state of mind of the woman who was suffering from battered woman syndrome at the time of the commission of the crime, the courts shall be assisted by expert psychiatrists/psychologists.

The legislative intent is unmistakable. Congress recognized that the lived realities of battered women do not always conform to the traditional paradigm of combat contemplated in the self-defense doctrine. x x x Consequently, Section 26 does not demand that the battered woman wait for a fatal attack before acting in preservation of life. To insist otherwise is to ignore the cyclical nature of domestic violence that the law itself was enacted to address.

(b) Two cycles of violence were established

The first cycle began its tension-building phase when AAA271087 became emotionally distant after his reassignment. x x x The violence escalated into the acute battering stage when on September 16, 2010, she discovered AAA271087 in a hotel room with another woman and, instead of receiving remorse, was restrained while she was physically assaulted. She sustained serious injuries which required her to seek hospital treatment. x x x

While the accused-appellant did not mention that she received an apology from her husband, the fact that the marriage and cohabitation continued after the hotel incident indicates a reconciliation period between husband and wife. The “contrition or honeymoon phase” need not involve grand gestures of remorse but may sometimes consist of merely a temporary calm between the couple.

Thereafter, the abuse continued behind closed doors. This is where the second cycle of the tension building phase begins. AAA271087 repeatedly came home late and physically abused accused-appellant for no apparent reason. x x x She did not seek police assistance because she feared retaliation and distrusted law enforcement due to her husband’s position as a police officer. x x x

The final violent confrontation in February 2011 constitutes another acute battering episode. AAA271087 shouted at their children and violently threw their youngest child onto a chair. When accused-appellant intervened by striking him with a ladle, she was assaulted. She then ran outside to ask help from her sister-in-law BBB271087. Afterwards, accused-appellant returned to the house and remained there, completing another cycle.

x x x

In the present case, the defense successfully established that the accused-appellant underwent at least two full cycles of battered woman syndrome. Given the duration of the abuse and the severity of the assaults she had sustained, this Court finds that the violence perpetrated by AAA271087 against accused-appellant were not isolated incidents but a systemic pattern. This fundamentally altered accused-appellant’s state of mind and caused her to have learned helplessness that led her to believe that only killing her husband would free her.

(c) Expert testimony on her state of mind

As instructed in Genosa and codified in Section 26 of the Anti-Violence Against Women and Their Children Act, the Court can find assistance from expert psychologists or psychiatrists to determine the state of mind of the woman that may be suffering from battered woman syndrome. The testimony of the expert serves as the bridge that explains why the victim, or, in this case, accused-appellant, acted the way she did.

In testifying that accused-appellant’s Major Depressive Disorder was a direct consequence of the physical, emotional, and psychological abuse she endured, Dr. Pagaddu showed that her actions were moved by self-preservation and desperation. After conducting multiple clinical interviews and a battery of psychiatric tests, the expert’s findings established a clear causal link between the husband’s “stormy” aggression and accused-appellant’s compromised mental state. x x x To her mind, shooting her husband was the only way she could finally bring an end to the cycle.

(d) The CA’s demand for corroboration was misplaced

The Court of Appeals’ high evidentiary requirement is misplaced.

Studies have shown that women in abusive relationships are unwilling to report violent instances due to a numerous of reasons including social stigma, lack of trust on authorities, humiliation, and cultural structures. Accordingly, one cannot expect those trapped in the cycle of violence would be able to report every beating or recount every traumatic memory. x x x Courts must be careful not to demand an impossible standard of proof detached from the realities of abuse. This becomes even more compelling where, as here, the alleged abuser occupied a position of authority as a police officer. The accused’s fear of reporting abuse to law enforcement cannot be dismissed as unreasonable.

This is consistent with the Philippines’ obligations under the Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW) x x x. CEDAW General Recommendation No. 35 further instructs States to ensure that evidentiary rules are not influenced by gender stereotypes or unrealistic expectations regarding victim behavior. x x x

The absence of exhaustive corroboration for every prior incident does not negate the existence of battered woman syndrome where the totality of the evidence, the documented injuries, the testimony regarding repeated abuse, the psychological findings, and the violent events immediately preceding the shooting, sufficiently establish a pattern of battering and coercive control.

Courts must interpret Republic Act No. 9262 with an awareness of the lived realities that compelled its enactment. x x x To deny the accused the protection of Section 26 simply because her abuse was not perfectly documented would be to impose upon battered women a burden the law itself never intended.

The Court granted the appeal, reversed the CA, acquitted XXX271087, and ordered her immediate release unless she is detained for another lawful cause.

Discussion:

1. Elements of parricide

All three elements were present and undisputed:

• (a) A person was killed. Present. AAA271087 died of multiple gunshot wounds, as shown by his death certificate.
• (b) The accused killed him. Present. XXX271087 admitted shooting him with his own gun. The prosecution witnesses saw her holding the gun right after the shots.
• (c) The victim is the legitimate spouse of the accused. Present. This was proven by the marriage certificate and by her own admission.

The case therefore turned on whether a defense would free her from liability. Admitting the killing shifts the burden to the accused to prove her defense.

Bar takeaway: When the accused admits the killing, list the elements briefly, then go straight to the defense.

2. Battered woman syndrome

First requirement under Genosa: each phase of the cycle of violence present in at least two battering episodes. Present.

The final episode that same night came when she tried to leave. He threatened that they would not leave the house alive and slammed her head against a wall.

Second and third requirements under Genosa: actual fear of imminent harm with an honest belief that force was needed, and probable grave harm based on the history of violence. The Court did not discuss these as separate items, but its findings address both:

• Actual fear and honest belief. The final attack came right after an explicit death threat and a head injury. Dr. Pagaddu testified that in XXX271087’s mind, “if the husband survived[,] she and her children will die.”
• Probable grave harm. Her husband’s history of beatings about four times a week, choking her, pointing a gun at her, and threatening to kill her showed probable grave harm. The harm did not need to be immediate.

The Court found that the abuse produced learned helplessness, which led her to believe that only killing her husband would free her.

Expert testimony. This was required by Section 26. Dr. Pagaddu conducted multiple interviews and a battery of psychiatric tests. She diagnosed major depressive disorder and traced it to the husband’s physical, emotional, and psychological abuse. This established the causal link between the abuse and her state of mind.

Corroboration. The CA wanted corroboration from relatives, neighbors, children, or police and medical reports. The Court held this standard unrealistic:

• Why abuse goes unreported. Battered women often do not report abuse because of stigma, distrust of authorities, humiliation, and trauma that can cause memory gaps.
• The abuser was a police officer. Her fear of going to the police was reasonable. Her neighbors were his sister and his colleague, which isolated her further.
• CEDAW General Recommendation No. 35. Evidentiary rules must not be shaped by stereotypes about how victims should behave.

The test is the totality of the evidence: documented injuries, her testimony on repeated abuse, the psychiatric findings, and the violence immediately before the shooting.

Effect. Under Section 26 of Republic Act No. 9262, she incurs no criminal and civil liability, even without the elements of self-defense. She was acquitted, and the civil awards fell with the conviction.

Comparison with Genosa. In Genosa, the Court found that the syndrome was not proved and that unlawful aggression was absent. It treated the circumstances only as mitigating, which reduced the penalty. This case shows the full effect of Section 26 once the syndrome is proved: complete exemption from liability, without needing unlawful aggression.

Bar takeaway: For a battered woman syndrome problem:

1. Map out at least two complete cycles, with all three phases in each.
2. Show her fear and belief at the time of the killing, using expert testimony.
3. Remember that under Section 26, the elements of self-defense are not required.

Do not reject the defense just because there are no police reports or witnesses. Courts look at the totality of the evidence.