MANILA — The Supreme Court has reiterated that a psychological evaluation is not required to prove that psychological violence was committed against a victim under Republic Act No. 9262 or the Anti-Violence Against Women and Their Children Act.

In a decision of the 3rd Division promulgated on August 12, 2024, the court affirmed the conviction of a man for psychological violence against his wife and children.

The court noted the accused’s extramarital affair, abandonment of his family and failure to provide financial support to his children, but he stressed that the prosecution did not support its argument through a psychological report.

The Supreme Court however reiterated its ruling on Labrador vs. People that a psychological evaluation is not indispensable in proving the infliction of psychological violence under the law..

“Further, the court has also categorically held that the victim’s testimony in court suffices to prove the element of emotional anguish,” the court said in the decision penned by Associate Justice Henri Jean Paul Inting.

The court emphasized that the accused’s wife gave a detailed testimony in court to prove her mental and emotional anguish.

The court noted that the wife recounted how her husband left their home to live with another woman right next door, fathered a child with her, and flaunted his affair on social media.

“Denial, being a self-serving negative defense, cannot be given greater weight than the declaration of credible witnesses who testify on affirmative matters,” the court said.

The accused was sentenced to imprisonment of six months to eight years and pay a fine of P200,000 and pay the victim moral damages amounting to P75,000.

He was also ordered to undergo mandatory counseling or psychiatric treatment and report his compliance to the court.