The Supreme Court (SC) has affirmed the conviction for psychological violence of a man who first reneged on his commitment to secure a license to marry a lady teacher he impregnated in 2020, withdrew the license when it was finally filed, and later married another woman.

Upheld by the SC was the conviction of the man for inflicting psychological trauma on the teacher in violation of Republic Act No. 9262, the Anti-Violence Against Women and their Children Act (VAWC) of 2004.

The SC, however, modified the penalty imposed by the Court of Appeals (CA) which upheld the ruling meted out by the regional trial court (RTC).

It imposed on the man a jail term of two years, four months and one day as minimum to nine years and four months as maximum.

He was also ordered to pay the teacher P75,000 in moral damages and P75,000 in exemplary damages with six percent interest annually until fully paid.

The names of the parties in the case docketed as GR No. E-00648 were redacted by the SC in the decision written by Associate Justice Ramon Paul L. Hernando and posted on the SC website – sc.judiciary.gov.ph – last August 17.

The CA had ruled that the man “was not being penalized for the breach of promise to marry itself, but for the consequential effects of his actions that led to the teacher being humiliated and publicly ridiculed.”

It also rejected the man’s contention that his act “was innocent, considering he knew the negative emotional effects his actions would cause the teacher and the scandal it would bring to her as a public- school teacher.”

In denying the petition filed by the man, the SC said that his arguments were laced with questions of fact and attempted to circumvent the rule by seeking a recalibration of the evidence already evaluated by the RTC and the CA.

It said the appeal claimed the lower courts misapprehended the facts and improperly applied the provisions of RA 9262 by convicting him for a breach of promise to marry and for expanding the application of the law to non-abusive or failed relationships resulting from incompatibility.

However, the SC said that RA 9262 “focuses on the effect of the offender's acts -- specifically the mental or emotional anguish caused to a woman with whom the offender had a sexual or dating relationship.”

“Since the lady teacher was pregnant and the withdrawal of the marriage application was done ‘arbitrarily’ and ‘publicly’ at the Local Civil Registrar, the act transcends simple heartbreak and enters the realm of ‘psychological violence,’” it also said.

At the same time, the SC rejected the man’s claim of “improper expansion” of RA 9262.

“The law is a protective statute; where an act -- even one involving marriage applications -- is used as a tool to inflict psychological trauma on a woman in a dating or sexual relationship, the law must be interpreted to hold the offender liable. The RTC and the CA did not penalize the petitioner for the breach of promise to marry itself. Section 5(i) of RA 9262 specifically penalizes acts that cause mental or emotional suffering,” the SC pointed out.

It noted that the RTC, as upheld by the CA, penalized the man because his "willful" withdrawal of the marriage license -- knowing that the teacher was pregnant and had already announced the union – “constitutes a form of emotional manipulation and public humiliation that fits the definition of psychological violence.”

The SC ruled: “Finally, the penalties of fine and the requirement of mandatory counseling, are all proper and in accordance with the law. The same applies to the grant of moral and exemplary damages, as these awards are supported by factual basis and prevailing jurisprudence. However, the penalty of imprisonment must be modified. Petitioner is sentenced to suffer the penalty of two years, four months and one day of prision correccional, as minimum, to nine years and four months of prision mayor, as maximum.”