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Monday, August 17, 2026

Withdrawal of Marriage Application Causing Emotional Trauma Constitutes Psychological Violence Under RA 9262

By LAPADIDAY August 17, 2026 No comments

Case: XXX v. People of the Philippines

G.R. No.: E-00648
Date: July 29, 2026
Ponente: Hernando, J., First Division
Law: Section 5(i), Republic Act No. 9262
Nature: Petition for Review on Certiorari

Facts

XXX, a police officer, and AAA, a public-school teacher, were in a romantic and sexual relationship. After AAA became pregnant, their families agreed that they should marry.

The couple applied for a marriage license after XXX had previously failed to appear on the agreed date. On the day they successfully lodged the application, however, XXX retrieved the documents and informed the Local Civil Registrar that the marriage would no longer proceed. He did so without notifying AAA, despite knowing that she was pregnant and had already announced their intended marriage to her family and friends.

AAA suffered humiliation, sleeplessness, loss of appetite, restlessness, depressive symptoms, and suicidal ideation. A social-welfare officer and a psychometrician confirmed her psychological and emotional distress.

The RTC convicted XXX of psychological violence under Section 5(i) of RA 9262. The Court of Appeals affirmed the conviction and awarded AAA moral and exemplary damages.

Issue

Whether XXX’s unilateral withdrawal of the marriage-license application constituted psychological violence under Section 5(i) of RA 9262, notwithstanding the rule that a breach of promise to marry is generally not actionable.

Ruling

Yes. The Supreme Court denied the petition and affirmed the conviction.

The Court held that XXX was not punished merely for breaking a promise to marry. He was held liable because his willful and arbitrary withdrawal of the marriage-license application—done after a public commitment, without notice, and with knowledge of AAA’s pregnancy—caused her serious mental and emotional suffering.

The prosecution established the elements of the offense:

XXX and AAA had a dating and sexual relationship;
XXX willfully withdrew the marriage-license application without notifying AAA after publicly committing to the marriage; and
His conduct caused AAA mental and emotional anguish, as demonstrated by her testimony and corroborated by professional assessments.

The act went beyond ordinary heartbreak or incompatible expectations. It amounted to emotional manipulation and public humiliation falling within the statutory definition of psychological violence.

Doctrine

A breach of promise to marry, by itself, is not the offense punished under Section 5(i) of RA 9262. Liability arises when an accused willfully uses conduct connected with the contemplated marriage as a means of inflicting mental or emotional anguish upon a woman with whom he has a dating or sexual relationship.

RA 9262 focuses on the psychological effect of the offender’s willful conduct upon the victim, not merely on the formal nature of the act committed.

Disposition

The conviction was affirmed with modification. XXX was sentenced to:

Imprisonment of two years, four months, and one day of prision correccional, as minimum, to nine years and four months of prision mayor, as maximum;
A fine of ₱100,000;
₱75,000 in moral damages and ₱75,000 in exemplary damages, with 6% annual legal interest from finality until full payment; and
Mandatory psychological counseling or psychiatric treatment.

FULL TEXT: https://sc.judiciary.gov.ph/e-00648-xxx-vs-people-of-the-philippines/

Am I Ready for Lawschool?

By LAPADIDAY July 27, 2026 No comments

"𝘋𝘰 𝘐 𝘏𝘢𝘷𝘦 𝘵𝘩𝘦 𝘙𝘪𝘨𝘩𝘵 𝘗𝘳𝘦-𝘓𝘢𝘸 𝘋𝘦𝘨𝘳𝘦𝘦?"

“𝘏𝘰𝘸 𝘥𝘰𝘦𝘴 𝘰𝘯𝘦 𝘱𝘳𝘦𝘱𝘢𝘳𝘦 𝘧𝘰𝘳 𝘭𝘢𝘸 𝘴𝘤𝘩𝘰𝘰𝘭?”

“𝘈𝘮 𝘐 𝘦𝘷𝘦𝘯 𝘲𝘶𝘢𝘭𝘪𝘧𝘪𝘦𝘥 𝘧𝘰𝘳 𝘭𝘢𝘸 𝘴𝘤𝘩𝘰𝘰𝘭?”

Over the years, people have asked me what they should do before entering law school. What books should they read in advance? What must they prepare to properly equip themselves for the battle that is law school?

I have also seen people lose heart because they believe they are not ready for the endeavor.

Perhaps much has changed through the years. Law school may no longer be the same as it was when I enrolled, and what I know from experience may already be outdated or irrelevant to today’s setup. Then again, no two law schools are exactly alike.

So, for the first time, I will share how I prepared for law school—based solely on my own experience. Perhaps, just perhaps, some of you might gain a little insight into what it is like to enter one of the most demanding academic realms: the School of Law.

So, how did I prepare?

I didn’t.

I am sorry if that comes as a disappointment, but it is true.

This piece is for anyone who feels ill-equipped to pursue law because of a lack of preparation, confidence in their stock knowledge, or whatever else they believe they should already possess.

It is written by someone who wanted to become a lawyer without even knowing that she would have to take the Bar examination to become one (yes, I didn’t know I had to take a licensure exam)—and yet, four years later, distinguished herself academically, passed the Bar, and now humbly serves in the country’s largest public law firm. I didn’t say this neither to brag nor to inspire. I say this only matter-of-factly to prove a point.

Everything I knew about becoming a lawyer, I learned in law school.

So, take heart and read on...

Apart from meeting the basic admission requirements at the time—such as having a bachelor’s degree and completing the prescribed general education units—I did nothing special before walking into class on my first day. I had done nothing I would say gave me an advantage. I entered the room, sat myself, and waited for the class to begin.

Would I have done things differently if I had been given the chance?

Probably not.

At that point, I do not think advance preparation would have made much of a difference. Had I been specifically instructed to read something beforehand, I would have done so. Other than that, I would not have lost heart simply because I had not read ahead.

This is not to say that law school came easily to me. It did not. But the difficulties I encountered were not the result of my failure to prepare before entering law school. Whatever preparation I needed, I learned to do along the way.

What carried me through the first-day jitters—and, eventually, through law school itself—was my desire to learn. That desire was rooted in my determination to become a lawyer.

Throughout those four years, I dedicated myself not only to learning the law but also to mastering 𝘩𝘰𝘸 to learn it. I humbled myself before the endeavor and focused on my own journey.

I refined the way I studied. I learned how to filter and select my materials. I improved the way I wrote my answers—both in substance and quite literally. I took the Bar when the examinations were still handwritten, and one’s handwriting could help determine whether one would make it or break it.

I dedicated myself to studying the law and to learning everything else I believed was essential to achieving my dream of becoming a lawyer.

There is, of course, nothing wrong with preparing early, reading in advance, or taking other steps to equip yourself. After all, nothing done in the pursuit of knowledge ever truly goes to waste.

But the people I most want to address are those who feel like giving up before they have even begun—those who believe they are not equipped for the pursuit, and those who think it is impossible to thrive because they have not met what they imagine to be the standard of a law student.

If I may be frank though, there is one quality I believe you must at least possess---and I say this not only of law school, but of every endeavor undertaken in the pursuit of learning:

You must have the humility to acknowledge that you are there to learn.

Only then can you become truly teachable.

You do not have to know everything before entering law school. You enter law school precisely because you are there to learn.

So, if becoming a lawyer is truly your dream, do not allow the fear of being unprepared to stop you before you have even begun.