EXPLAINER: When can battered woman syndrome be used as a defense in parricide cases?

MANILA —  The Supreme Court’s Second Division recently reversed the decisions of the Court of Appeals and the Regional Trial Court, which found a woman guilty of parricide.

The high court acquitted the woman mainly on the basis of “battered wife syndrome” or “battered woman syndrome.”

Under Republic Act No. 9262, or the Anti-Violence Against Women and Their Children Act of 2004, victim-survivors found by the courts to be suffering from battered woman syndrome do not incur criminal or civil liability.

SECTION 26. Battered Woman Syndrome as a Defense. Victim-survivors who are found by the courts to be suffering from battered woman syndrome do not incur any criminal and civil liability notwithstanding the absence of any of the elements for justifying circumstances of self-defense under the Revised Penal Code. In the determination of the state of mind of the woman who was suffering from battered woman syndrome at the time of the commission of the crime, the courts shall be assisted by expert psychiatrists/psychologists.

In its decision promulgated on July 14, 2026, the high court said the Court of Appeals erred in affirming the RTC’s decision, citing the insufficiency of the psychological report and the wife’s declarations to support her claim of battered woman syndrome.

The SC said the CA’s high evidentiary requirement was “misplaced.”

The SC also stressed that the law seeks to prevent the deaths of women subjected to abusive relationships.

“Consequently, Section 26 does not demand that the battered woman wait for a fatal attack before acting in preservation of life,” the SC said in the decision penned by Senior Associate Justice Marvic Leonen.

The court noted that battered woman syndrome was recognized in the landmark case People v. Genosa.

A battered woman was defined as a woman “who is repeatedly subjected to any forceful physical or psychological behavior by a man in order to coerce her to do something he ·wants her to do without concern for her rights.”

In the Genosa case, however, the court ultimately found that the victim failed to prove the existence of the syndrome and that unlawful aggression was lacking.

For battered woman syndrome to be considered as a defense, there must be clear evidence establishing the history of abuse and its psychological effects on the appellant.

• Tension-building phase
• Acute battering incident
• Non-violent phase

Tension-building phase — This is where tension and conflict begin to build in the relationship. The abuser becomes increasingly irritable, angry, and unpredictable. The woman may try to placate the abuser, avoid conflict, or stay out of his way to prevent an escalation. She may regard the abuse during this phase as only minor occurrences, allowing the pattern of abuse to worsen.

Acute battering incident — This phase is characterized by brutality and, in the worst cases, death. Tension reaches its breaking point, prompting the abuser to release the built-up tension through a violent outburst. This may include physical, sexual, and emotional abuse or other forms of aggression.

Non-violent or reconciliation phase — During this phase, the abuser may apologize, express remorse, or promise never to hurt the victim again. They may shower the victim with affection, gifts, or attention to make up for the abuse. The victim, wanting to believe the abuser’s promises, may choose to remain in the relationship.

Under the law, at least two cycles of violence must be established.

Court records indicate that the first cycle began when the husband’s cold demeanor created instability in the marriage following rumors of his infidelity.

The violence escalated in 2010 when the wife discovered her husband in a hotel room with another woman.

In 2012, the wife obtained a medical certificate showing that she had been brought to a hospital, where she was diagnosed with hematomas and lacerated wounds.

The abuse continued even without apparent provocation, but the wife did not seek police assistance because she feared retaliation.

The final violent confrontation happened in 2011 when the husband violently threw their youngest child onto a chair, prompting the wife to strike him with a ladle. However, she was instead assaulted.

Following the confrontation, the wife decided to pack her clothes and leave their house, but her husband threatened that she would not be able to get out of the house alive.

The husband then began beating his wife, slamming her head against the wall and causing her vision to blur.

The wife claimed that her memory went blank and that when she regained consciousness, she was already at the police station.

The court said the defense successfully established that the accused-appellant underwent at least two full cycles of battered woman syndrome.

“This fundamentally altered accused-appellant’s state of mind and caused her to have learned helplessness that led her to believe that only killing her husband would free her,” the SC said.

The SC emphasized that courts must be careful not to demand an impossible standard of proof from women victim-survivors of abusive relationships.

The court said a woman trapped in an abusive relationship cannot be expected to report every beating to authorities or recount every traumatic memory in open court.

“Stigma, distrust of authorities, humiliation, and cultural pressures are some reasons that deter women from seeking help and push them to remain silent,” the SC said.