XXX vs. People p1
XXX vs. People p1
XXX vs. People p1
Facts:
1. An Information was filed against XXX for violation of Section 5(i) of RA 9262 or the Anti-Violence
Against Women and their Children Act.
2. Private complainant YYY is the legal wife of petitioner. Sometime in October 2010, petitioner
started a fight with YYY, as it is his usual habit when he is intoxicated. Petitioner drove YYY and
her four children, AAA, BBB, CCC, and DDD, out of the house and claimed the he alone owned the
house.
3. YYY, along with her daughters, fled to her parent's house. However, the spouses' eldest child, EEE,
convinced his three sisters to return to their house so their father will be forced to support them,
leaving CCC with their mother.
4. Later on, YYY's daughters, particularly AAA, reported to her through text messages that
petitioner was always drunk and even brought them to a videoke bar and introduced one Pearl
Manto as their aunt. She thereafter learned from her daughter that the same woman was already
eating lunch for two months in their house and ultimately lived with them.
5. Both the RTC and CA found petitioner guilty beyond reasonable doubt.
6. Petitioner now posits that the RTC and CA decisions were based on hearsay evidence
a. the presence of psychological violence has not been duly proven beyond reasonable
doubt by the prosecution.
b. that the wife YYY could not have suffered psychological violence since she did not have
personal knowledge of the existence of the crime or of his alleged marital infidelity. YYY
only came to know of his alleged marital infidelity through their daughter AAA, who sent
text messages to her mother regarding his father's mistress.
Issue:
Whether or not YYY’s statements are admissible as evidence
Ruling:
Yes, YYY’s statements are admissible as evidence against XXX.
Under the doctrine of independently relevant statements, only the fact that such statements
were made is relevant, and the truth or falsity thereof is immaterial. The doctrine on independently
relevant statements holds that conversations communicated to a witness by a third person may be
admitted as proof that, regardless of their truth or falsity, they were actually made. Evidence as to the
making of such statements is not secondary but primary, for in itself it (a) constitutes a fact in issue or (b)
is circumstantially relevant to the existence of such fact. Accordingly, the hearsay rule does not apply,
and hence, the statements are admissible as evidence.
In this case, YYY indeed did not have personal knowledge of the marital infidelity of petitioner.
YYY's statement may be considered an independently relevant statement, an exception to the hearsay
rule, the purpose of which is to merely establish that a statement was made. YYY was only testifying that
she and her children were driven out of their home and thereafter she learned through her daughter AAA
that her husband, petitioner, is having an affair with Pearl, who eventually lived with her husband and
their children in their conjugal home.