[CASE DIGEST] Sedenio versus People of the Philippines, G.R. No. 276927, January 19, 2026

 

Janito M. Sedenio versus Peoples of the Philippines

G.R. No 276927

January 19, 2026

Rosario, J.

 

Facts:

The petitioner was charged with violation of Section 5 (h)(5) of the RA No. 9262. Upon arraignment, he pleaded not guilty. The Regional Trial Court (RTC) found Sedenio guilty beyond reasonable doubt. Sedenio appealed before the Court of Appeals (CA). However, the CA denied his appeal and affirmed the decision of the (RTC). Hence, the petitioner filed a petition for Certiorari questioning the CA’s Decision and resolution.

Issue:

Whether the CA erred in finding petitioner guilty beyond reasonable doubt of violating Section 5(h)(5) of R.A. No. 9262.

Ruling:

The Supreme Court denied the petition.

Procedural Aspect:

A.     The petition fails to comply with several requirements under the Rules of Court.

1.       The petitioner failed to attached proof of service to the court of origin. The ROC requires that petition for review be accompanied by proof of service on the adverse party and the lower court concerned.

2.       The petition contains an incomplete statement of material dates. The ROC provides that a petition for review must indicate the material dates showing when the (a) notice of judgment, final order, or resolution subject of the petition was received; (b) when a motion for new trial or reconsideration was filed; and (c) and when notice of the denial thereof was received. None compliance with the foregoing requirement is sufficient ground for the dismissal of the Petition. The petitioner failed to provide the dates when the notice of assailed judgment was received and when the MR was filed.

 

B.      The subject text messages were sufficiently proven.

The petitioner argued that under Rule 11, Section 2 of the Rules on Electronic Evidence, all ephemeral electronic evidence, such as text messages, need to be presented to the court to be identified and authenticated by the person to testify on the accuracy thereof and pursuant to jurisprudence, text messages need to be proven by the testimony of the person who was a party to the conversation or has the personal knowledge of the same. However, the prosecution failed to prove that the alleged text messages were sent with intent to harass.

The Court ruled that under the Rules on Electronic Evidence, text messages shall be proven by the testimony of a person who was a party to the same or has personal knowledge thereof. In this case, AAA, who was a party to the subject text messages and has personal knowledge of the same, being the intended recipient, sufficiently proved such testimony through her testimony. In fact, the petitioner admitted that the mobile number used to send AAA the subject text messages was his own number and that he sent such “humiliating and threatening words” to AAA because he felt hurt and was often drunk when texting her during the cross-examination. Thus, the petitioner cannot go back on his judicial admission, there being no showing that such admission was made through palpable mistake or that the imputed admission was not, in fact made.

C.     The information need not state that the petitioner and AAA were no longer in a relationship at the time of filing of the same.

The petitioner argued that the absence in the Information of the fact that he and AAA were no longer in a relationship at the time the Information was filed was violative of his right an accused to be informed of the nature and cause of his accusation.

Substantial Aspect:

            The elements of violence against women through harassment are: (1) the offender has or had a sexual or dating relationship with the offended woman; the offender, by themselves or through another, commits an act or series of acts of harassment against the woman; and (3) the harassment causes her alarm or substantial emotional or psychological distress.

            One element of the said crime is either a present or past sexual or dating relationship with the offended woman. Thus, as long at the time the alleged crime was committed, the offender and the offended woman either were or used to be in a sexual or dating relationship. This element is present.

            The Information clearly stated that at the time of the commission of the crime, petitioner and AAA were in a dating relationship, and that petitioner personally sent threatening and derogative text messages to the latter causing her alarm and substantial emotional or psychological distress. Whether he and AAA were still in a dating relationship at the time the Information was filed is immaterial.

Petitioner is guilty of violating Section 5(h)(5) of RA 9262

The elements of violence against harassment are present in this case. First. It is undisputed that petitioner and AAA were in a sexual or dating relationship. Both the petitioner and AAA testified that they were in a clandestine romantic relationship for about two years’ despite being married to other people. Second. The prosecution sufficiently established through AAA’s testimony - as well as petitioner’s judicial admission - that petitioner sent AAA multiple text messages constituting harassment from July to August 2012. Third. The harassment inflicted upon AAA by the petitioner caused her alarm or substantial emotional or psychological distress.

Under the law psychological violence refers to acts or omissions that cause or are likely to cause the victim’s mental or emotional suffering. One such form of psychological violence is harassment.

The court held that in cases of psychological violence, proof that the victim became psychologically ill as a result of psychological violence sustained by her is not required. Thus, to prove emotional anguish or mental suffering, jurisprudence only requires that the testimony of the victim be presented in court, as their experiences are personal to them. Hence, AAA’s testimony - if found credible by the court - is sufficient to establish the element of alarm or substantial or psychological distress.

The petition is denied and the Decision and Resolutions of the Court of Appeals are affirmed with modification.

 

Takeaway: The law (RA 9262) does not only protect the legal wife/original partner but it also protects the mistress or those who have illicit affairs. Because the law does not distinguish whether such sexual or dating relationship is legal or an illicit one.