The Supreme Court has reversed the conviction of a woman found guilty of parricide, ruling that she was suffering from battered woman syndrome at the time she fatally shot her husband and is therefore exempt from criminal and civil liability under Section 26 of Republic Act No. 9262.
In a decision in G.R. No. 271087, the Court granted the appeal, set aside the Court of Appeals' August 9, 2023 Decision, and acquitted the accused-appellant, ordering her immediate release from detention unless held for some other lawful cause.
The Case
In a February 23, 2011 Information, the accused-appellant was charged with parricide. The accusatory portion stated that on or about February 8, 2011, she willfully, unlawfully and feloniously, with intent to kill, shot her legitimate husband several times with a 9mm pistol, hitting him on different parts of his body, inflicting fatal wounds that caused his immediate death. She pleaded not guilty on arraignment.
The prosecution presented three witnesses: the victim's sister-in-law, the arresting officer Police Officer II Sheryl Respicio, and the victim's mother. According to the prosecution, the crime started from an argument between the spouses. On February 8, 2011, at 9:00 p.m., the sister-in-law heard the accused screaming, then found the victim with blood on his body. A few moments later she heard several gunshots and, upon opening the door, saw the accused with a gun in her hand. The victim's Certificate of Death showed multiple gunshot wounds in the head, right upper extremity, thorax, abdomen, and right and lower extremities.
The defense presented the accused and interposed the defense of battered woman syndrome, supported by the psychiatric report of government psychiatrist Dr. Emery I. S. Layugan and Dr. Ethel Maureen Pagaddu, who assisted him. The accused testified that she and her husband had been married for 11 years and had three sons, that the relationship soured when he was assigned elsewhere, and that he became violent, beating her about four times a week. On the day of the incident, she said he threw their two-year-old son on a chair, threatened her, beat her, and slammed her head against a wall, after which her memory went blank.
The Issue
The central question was whether the accused was suffering from battered woman syndrome and thus exempt from criminal and civil liability, and whether the courts below erred in requiring exhaustive corroboration of the abuse she claimed to have endured.
The Ruling
The Court held that the Court of Appeals erred when it affirmed the lower court's decision to convict. It found that the appellate court's high evidentiary requirement was misplaced, ruling that the totality of the evidence sufficiently established a pattern of battering and coercive control.
The dispositive portion reads: "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 XXX:271087 is ACQUITTED." The Court ordered her immediately released from detention unless confined for some other lawful cause, and directed that copies of the decision be furnished to the Director General of the Bureau of Corrections for immediate implementation, with a report to the Court within five days from receipt.
By the Numbers
- G.R. No. 271087
- Information dated February 23, 2011
- Date of the incident: February 8, 2011
- Weapon: 9mm pistol
- Married 11 years, three sons
- Regional Trial Court Decision: January 21, 2020 (Crim. Case No. 19-7211)
- Court of Appeals Decision: August 9, 2023 (CA-G.R. CR-HC No. 14921)
The Court's Reasoning
The Court explained that, as instructed in Genosa and codified in Section 26 of the Anti-Violence Against Women and Their Children Act, courts may rely on expert psychologists or psychiatrists to determine the state of mind of a woman who may be suffering from battered woman syndrome. It gave weight to the court-appointed expert who diagnosed the accused with major depressive disorder and found that the abuse she suffered moved her to inflict the fatal shots.
The Court noted that women in abusive relationships are often unwilling to report violent instances due to social stigma, lack of trust in authorities, humiliation, and cultural structures, and that victims may remain silent or forget details as the mind withdraws to shield itself from unbearable pain. It said the absence of exhaustive corroboration does not negate battered woman syndrome where the totality of the evidence establishes a pattern of battering and coercive control, and emphasized that the alleged abuser occupied a position of authority as a police officer.
The Court added that this interpretation is consistent with the Philippines' obligations under the Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW), which instructs that evidentiary rules not be influenced by gender stereotypes or unrealistic expectations of victim behavior. It concluded 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.
Source: Supreme Court Decision, G.R. No. 271087.
This report summarizes a public Supreme Court decision and is not legal advice.