Araza Vs People

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International Women's Day

[ G.R. No. 247429,


September 08, 2020 ]
JAIME ARAZA Y
JARUPAY, PETITIONER,
VS. PEOPLE OF THE
PHILIPPINES,
RESPONDENT.
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October 5, 1989 - Araza and the


complainant were married

AAA received a text message from a certain


Edna and Mary Ann, who told her that
Araza was having an affair with their best
friend

September 3, 2007- confirmed that Araza


was living with certain Tessie Luy Fabillar
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Concubinage- was filed against
Araza and Fabillar

November 22, 2007- Araza left his


wife

June 20, 2014- AAA filed a Petition


for Habeas Corpus, thinking that
Fabillar was restraining the liberty of
Araza
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June 20, 2014. The [CA] deputized
NBI agent to conduct a thorough
investigation on Araza and
Fabillar
Based on the investigation- Araza
left their conjugal abode of his own
volition, and he has been living with
his mistress as husband and wife.
As a matter of fact, three children
were born out of their cohabitation.
Hence, the petition for habeas
corpus was dismissed.
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The truth caused AAA emotional
and psychological suffering.
She was suffering from insomnia
and asthma.
Allegedly, she is still hurting and
crying and could not believe what
had happened in their marriage as
they were living harmoniously as
husband and wife.
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She was taking anti-depressants
and sleeping pills to cope with the
severe emotional and psychological
turmoil brought about by Araza's
marital infidelity and having
children with his mistress.

She claimed she had spent a large


amount of money to search for her
husband, which includes the filing
of several cases.
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The defense presented Araza as it
sole witness. According to Araza
that:

He and AAA were married in


1989;

He was a former taxi driver and an


OFW for [two] years. When he
stopped being an OFW, he went
back to being a taxi driver
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when he was in Cagayan de Oro to
recruit agents for their business,
AAA had told him that his sister
had a stroke.

He was allegedly dismayed when his


wife did not even offer any help, as
she claimed she had nothing to
spare.
He felt hurt about it and sadly, his
sister died
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In 2007- his relationship with his
wife went sour, and AAA believed
in rumors and accused him of being
a womanizer.

He denied having an affair with


Fabillar

when AAA went to Zamboanga,


she filed a complaint against him
and he was arrested as a
consequence and was forced to sign
an agreement.
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He returned to Manila with his
wife, hoping that she would change
her ways towards him, but she did
not.

Eventually, he sought his friend’s ]


help to secure a plane ticket [ound
to Zamboanga. He left his wife
because he could no longer stand
[her] attitude towards him. He also
denied fathering children with
Fabillar.
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RTC Ruling:
October 30, 2017
all the elements of the crime of
violence against women under
Section 5(i) of R.A. No. 9262 were
satisfied.
With regard to AAA's testimony,
the RTC is convinced by her
sincerity and candor.
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Her testimony was able to show that
due to Araza's acts of infidelity, she
suffered emotional and
psychological harm

Since there are no facts and/or


circumstances from which it could
be reasonably inferred that AAA
falsely testified or was actuated by
improper motives, her testimony is
worthy of full faith and credit.
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Araza- defense of denial
cannot be given greater weight
than the declaration of a
credible witness who testifies on
an affirmative matter.

Araza- GUILTY beyond


reasonable doubt for Violation of
Section 5(i) of Republic Act 9262
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Ruling of the CA
-denied Araza's appeal, and motion
for reconsideration, in toto.

- found that the prosecution


sufficiently established the elements
of the crime as defined in Section
5(i) of R.A. No. 9262, and as alleged
in the Information filed against
Araza
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The CA concluded that
-R.A. No. 9262 does not criminalize
acts such as the marital infidelity
per se
-but the psychological violence
causing mental or emotional
suffering on the wife.
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Supreme Court
Petition is denied for lack of
merit.
The elements of violation of
Section 5(i) of R.A. No. 9262
were sufficiently alleged in the
Information
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In Dimamling v. People the elements of violation of Section
5(i) of R.A. No. 9262 are enumerated:
(1) The offended party is a woman and/or her child or
children;
(2) The woman is either the wife or former wife of the
offender or is a woman with whom the offender has had a
sexual or dating relationship, or is a woman with whom such
offender has a common child. As for the woman's child or
children, they may be legitimate or illegitimate, or living
within or without the family abode;
(3) The offender causes on the woman and/or child mental
or emotional anguish; and
(4) The anguish is caused through acts of public ridicule or
humiliation, repeated verbal and emotional abuse, denial of
financial support or custody of minor children or access to
the children or similar acts or omissions.
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The CA was correct in ruling that Araza committed


psychological violence upon his wife, AAA, by committing
marital infidelity, which caused AAA to suffer emotional
anguish and mental suffering.

Psychological violence is an indispensable element of


violation of Section 5(i) of R.A. No. 9262. Equally essential
is the elements of emotional anguish and mental suffering,
which are personal to the complainant.

The law does not require proof that the victim became
psychologically ill due to the psychological violence done by
her abuser. Rather, the law only requires emotional anguish
and mental suffering to be proven
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The prosecution has established Araza's guilt beyond
reasonable doubt by proving that he committed
psychological violence upon his wife by committing
marital infidelity.

AAA's testimony was strong and credible.

She was able to confirm that Araza was living with


another woman.

Marital infidelity, which is a form of psychological


violence, is the proximate cause of AAA's emotional
anguish and mental suffering, to the point that even
her health condition was adversely affected

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