SC acquits woman of parricide over ‘battered wife syndrome’ defense

MANILA — The Supreme Court has acquitted a woman of parricide or killing her husband after the court determined that she suffered from “battered wife syndrome.”

The 2nd Division, in a decision promulgated on July 14, granted the appeal of the woman earlier found guilty of parricide by the Regional Trial Court in 2020 and sentenced to suffer reclusion perpetua.

The SC, in the decision penned by Senior Associate Justice Marvic Leonen, ordered her released immediately unless she is confined for some other lawful cause.

The RTC decision convicting the woman of parricide was affirmed by the Court of Appeals which also modified the ruling by increasing the total amount of exemplary and temperate damages she has to pay from P30,000 and P25,000 to P75,000 and P50,000

The SC however said the woman’s appeal is with merit because even if she admitted killing her husband, the emotional and physical abuse she suffered led her to end his life by shooting him with his own gun. 

The high court also noted that Section 26 of Republic Act No. 9262 or the Anti-Violence Against Women and Their Children Act of 2004 expressly provides that a victim found suffering from battered woman syndrome shall not incur criminal and civil liability.

“Consequently, Section 26 does not demand that the battered woman wait for a fatal attack before acting in preservation of life,” the SC said.

The court also noted that the battered woman syndrome was recognized in the landmark case People vs. Genosa and 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.”

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

For the battered wife syndrome to be considered as a defense, there must be clear evidence proving the history of abuse and psychological effect of the battery on the appellant.

In the present case however, the appellant successfully satisfied all three phases required – tension-building phase, accute battering incident and non-violent phase.

Under the law, at least two cycles of violence should be proven.

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

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

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

The abuse continued even without apparent reasons but the wife did not seek police assistance because of fear of retaliation.

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

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

The husband started to beat his wife, slamming her head against the wall and causing her vision to blur.

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

The court further stated that 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 also stated that the CA erred when it affirmed the RTC’s decision because of the insufficiency of the psychological report as well as declarations made by the wife to support her claim of battered woman syndrome. 

“The Court of Appeals’ high evidentiary requirement is misplaced,” the SC said.