XXX, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

XXX versus People of the Philippines

The Case

This is a criminal case in which a man, identified only as XXX to protect the privacy of the parties, was charged with psychological violence against a woman, identified only as AAA, under the Anti-Violence Against Women and their Children Act of 2004. The prosecution's theory was that XXX, a police officer who had a sexual and dating relationship with AAA and who had impregnated her, inflicted mental and emotional abuse upon her when he unilaterally withdrew their application for a marriage license at the Local Civil Registrar, after the couple and their families had publicly committed to the marriage. The case matters because the Supreme Court had to decide whether that act of withdrawing a marriage license application can constitute psychological violence under the law, or whether it is merely a breach of a promise to marry, which is not an actionable wrong.

Procedural History

XXX was charged before the Regional Trial Court with violation of Section 5 (i) of Republic Act Number 9262. At arraignment he refused to enter a plea, so the trial court entered a plea of not guilty on his behalf. After trial, the Regional Trial Court convicted him beyond reasonable doubt and sentenced him to an indeterminate penalty of two years, four months and one day of prision correccional medium as minimum, to ten years and one day of prision mayor maximum, as maximum, and ordered him to pay a fine of 100,000 pesos and to undergo mandatory psychological counseling.

XXX appealed his conviction to the Court of Appeals. In its decision dated April 30, 2025, the Court of Appeals affirmed the conviction but modified the award, adding moral damages of 75,000 pesos and exemplary damages of 75,000 pesos, and imposing legal interest on the monetary awards. XXX moved for reconsideration, but the Court of Appeals denied the motion in its resolution dated September 16, 2025. XXX then filed a petition for review on certiorari before the Supreme Court, which is how the case reached the highest court.

Facts

Sometime in 2019, XXX, a police officer, and AAA, a public school teacher, entered into a romantic relationship after four months of courtship. In April 2020, AAA discovered that she was pregnant, and the news was positively received by the couple. Initially the relationship was harmonious, and XXX frequently visited AAA's home to attend to her needs during her pregnancy. In May 2020, however, AAA suddenly lost contact with XXX, and it was only during the last week of that month that he reconnected with her and took her for a medical check-up. During this time they visited XXX's house, where AAA met his parents.

On May 28, 2020, XXX and his family visited AAA's home to meet her parents. Both families agreed that the couple should marry, and they scheduled a visit to the Local Civil Registrar on June 1, 2020, to apply for a marriage license. On the appointed date, AAA was informed by XXX's colleagues that he had been called to a police operation and could not attend. This shocked AAA, because XXX had assured her he would seek permission from his superiors to be relieved of duty for the wedding preparations, and she felt utterly humiliated and ashamed, having already informed her family and friends of the impending marriage license application.

Six days later, XXX reached out to AAA, apologized for his absence, and requested a new schedule. On June 11, 2020, they successfully lodged their application. The following day, however, AAA learned that XXX had withdrawn it. Upon verification with the Local Civil Registrar, AAA confirmed the withdrawal, as XXX had reportedly claimed that AAA was aware of his actions and that his family and friends did not favor the union. AAA subsequently filed the case. She was examined by a Municipal Social Welfare and Development Office officer, who testified that AAA was shaking and emotionally distraught while recounting her experiences and was not in a stable psychological and emotional state. A psychometrician testified that her tests revealed restlessness, suicidal ideation, and depressive symptoms, which she attributed to the postponed marriage and AAA's anxiety regarding her second pregnancy out of wedlock. An employee of the Local Civil Registrar confirmed that although he processed the couple's application, XXX returned the same day to retrieve the documents, stating that the marriage would not proceed.

Issues

• Whether or not the Court of Appeals erred in affirming the conviction despite the rule that a breach of promise to marry is not an actionable wrong.
• Whether or not there was a breach to speak of, since the application for a marriage license was not consensual.
• Whether or not the elements of the crime were proven beyond reasonable doubt, given the alleged lack of malicious intent in the withdrawal of the birth certificate.
• Whether or not the effects of his actions were deliberate or willful, such that he ought not to be penalized for how AAA reacted to them.
• Whether or not his conviction was an improper expansion of Republic Act Number 9262, penalizing acts that are not abusive but simply the unfortunate and painful consequences of incompatible expectations in a relationship.
• Whether or not he is entitled to acquittal based on reasonable doubt.

Applicable Provisions

Section 5 (i) of Republic Act Number 9262, the provision under which XXX was charged and convicted, provides:

Section 5. Acts of Violence Against Women and Their Children. The crime of violence against women and their children is committed through any of the following acts: (i) Causing mental or emotional anguish, public ridicule or humiliation to the woman or her child, including, but not limited to, repeated verbal and emotional abuse, and denial of financial support or custody of minor children of access to the woman's child or children.

This provision defines the crime and supplies its elements, and the entire case turns on whether XXX's act of withdrawing the marriage license application falls within the mental or emotional anguish, public ridicule or humiliation that it penalizes.

Ruling

The Supreme Court denied the petition. On the first and sixth issues, the Court held that the petition raised factual issues, and that in a petition for review on certiorari under Rule 45 the Court's jurisdiction is generally limited to questions of law. The Court is not a trier of facts and generally accepts the factual findings of the Court of Appeals and the trial courts as final and conclusive. XXX's arguments were laced with questions of fact, attempting to circumvent the rule by seeking a recalibration of evidence already evaluated below, and he failed to demonstrate that the case fell within any recognized exception.

On the second, third, fourth, and fifth issues, the Court held that Republic Act Number 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 AAA 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. The Court found that the prosecution established the elements of Section 5 (i): first, XXX admitted that he and AAA had a sexual or dating relationship; second, he withdrew the marriage license application without notice after a public commitment; and third, the acts resulted in AAA's emotional anguish, as established by her testimony and confirmed by the social welfare officer and the psychometrician, who found suicidal ideation, depressive symptoms, and restlessness because of XXX's act.

The Court rejected the argument that the law was improperly expanded. It held that the law is a protective statute, and that 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 Court clarified that the trial court and the Court of Appeals did not penalize XXX for the breach of promise to marry itself. Section 5 (i) specifically penalizes acts that cause mental or emotional suffering, and XXX was penalized because his willful withdrawal of the marriage license, knowing that the victim was pregnant and had already announced the union, constituted emotional manipulation and public humiliation that fits the definition of psychological violence. The Court also held that the fine and the requirement of mandatory counseling were proper and in accordance with law, as were the awards of moral and exemplary damages, which were supported by factual basis and prevailing jurisprudence. However, the Court modified the penalty of imprisonment.

Doctrine

A breach of a promise to marry is not itself an actionable wrong, and a person is not punished for the broken promise. But when the act of withdrawing a marriage license application is done willfully, arbitrarily, and publicly, knowing that the woman is pregnant and has already announced the union, and it causes her mental or emotional anguish, public ridicule, or humiliation, that act constitutes psychological violence under Section 5 (i) of Republic Act Number 9262. The law is a protective statute, and it focuses on the effect of the offender's acts on a woman with whom he had a sexual or dating relationship. The elements of the offense are: a sexual or dating relationship between the offender and the woman; an act causing mental or emotional anguish, public ridicule, or humiliation; and proof of the resulting anguish. Finally, a petition for review on certiorari under Rule 45 is confined to questions of law, and factual findings of the trial court and the Court of Appeals are final and conclusive absent a demonstrated exception.

Disposition

The petition was denied, and the conviction of XXX for violation of Section 5 (i) of Republic Act Number 9262 was affirmed, with the modification that he is sentenced to an indeterminate 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.

Remember This

The single line worth memorizing is that the law punishes not the broken promise to marry but the psychological violence inflicted when the withdrawal of the marriage license application is willful, arbitrary, and public. Examiners like to use this case to test the distinction between a non-actionable breach of promise to marry and psychological violence under Section 5 (i) of Republic Act Number 9262, and to test the Rule 45 limitation to questions of law.