* The Supreme Court upheld the conviction of a police officer under RA 9262 for psychological violence after he arbitrarily and publicly withdrew a marriage license application without notifying his pregnant partner.
* Lower courts found the officer's actions caused the public school teacher severe emotional anguish, psychological distress, and mental harm, which ultimately contributed to the loss of her unborn baby.
* The Supreme Court modified the officer's prison sentence to 2 years, 4 months, and 1 day minimum up to 9 years and 4 months maximum, ordering ₱250,000 in fines and damages.
THE Supreme Court (SC) has upheld the conviction of a police officer for psychological violence after he withdrew a marriage license application without telling his pregnant partner, ruling that his actions went beyond a broken promise to marry.
In this ruling, the High Court’s First Division drew a distinction between simply deciding not to marry and committing acts that cause mental or emotional anguish punishable under Republic Act (RA) 9262, or the Anti-Violence Against Women and Their Children Act.
It denied the police officer’s petition to reverse the decision of the Court of Appeals (CA), which upheld a lower court’s decision to convict him.
“Since (the woman) was pregnant and the withdrawal of the marriage application was done ‘arbitrarily’ and ‘publicly’ at the LCR (Local Civil Registrar), the act transcends simple heartbreak and enters the realm of ‘psychological violence,’” the SC said in its decision promulgated on July 29, 2026.
The identities of the police officer and his estranged partner, a public school teacher, along with details that could identify them, remain withheld under rules protecting victims in cases involving violence against women and children.
Start of the relationship
In 2019, the police officer and the teacher entered into a romantic relationship.
The teacher learned she was pregnant in April 2020. On May 28, both families met and agreed that the couple should marry.
The couple then planned to go to the LCR on June 1 to apply for a marriage license. The police officer did not appear on the scheduled date, and his colleagues later told the woman that he had been called to a police operation.
According to the SC’s decision, the woman felt humiliated and ashamed because she had already told family and friends about the planned marriage license application.
Six days later, the police officer contacted her and apologized for his absence. He asked the teacher that they set another date.
The couple eventually filed their marriage license application on June 11, 2020. On the following day, the woman learned that the police officer had withdrawn it. When she checked with the LCR, she was told that he had said she knew about the withdrawal and that his family and friends did not favor the marriage.
An employee of the LCR also testified that the police officer returned after the application was processed and retrieved the documents, saying the marriage would not proceed.
Emotional impact
A Municipal Social Welfare and Development Office employee who assessed the teacher testified in court that she was shaking and emotionally distraught while recounting what happened.
The employee recommended a psychiatric evaluation and said the teacher was “not in a stable psychological and emotional state.” A psychometrician who examined her found restlessness, suicidal ideation and depressive symptoms.
The Regional Trial Court (RTC) later found that the police officer’s withdrawal of the application caused psychological harm. It added that the teacher felt ashamed and belittled. She also had sleepless nights and lost her appetite, the RTC said.
Why lower courts convicted the officer
The RTC convicted the police officer on Dec. 4, 2023, of violating Section 5(i) of RA 9262. The CA affirmed the conviction on April 30, 2025. In discussing the award of damages, the appellate court also cited the emotional anguish and stress suffered by the woman that led to the death of her baby.
For his part, the police officer argued that he should not be convicted because a breach of a promise to marry is not an actionable wrong. He also denied that he deliberately withdrew the marriage application, saying he had only retrieved his birth certificate.
The CA rejected those arguments. It found that the unexplained withdrawal of the marriage license application was the means by which the woman suffered emotional and mental anguish, adding that the police officer was not being punished simply for failing to marry her, but for the consequences of his actions.
The CA also noted that the police officer married another woman only months after the marriage application was withdrawn. The appellate court said that circumstance undermined his claim that his actions had been innocent.
SC upholds the conviction
The SC said RA 9262 focuses on the effect of an offender’s acts, particularly the mental or emotional anguish caused to a woman with whom he has had a sexual or dating relationship.
It found that prosecutors established that the police officer and the woman had such a relationship and that he withdrew the marriage license application without notice after a commitment done in the presence of their families.
The High Court also found that the withdrawal caused emotional anguish supported by the woman’s testimony and assessments by the social welfare employee and psychometrician.
It said that “the RTC and the CA did not penalize petitioner for the breach of promise to marry itself.” Instead, the High Court said the police officer’s “willful” withdrawal of the marriage license, despite knowing the woman was pregnant and had already announced their planned marriage, amounted to emotional manipulation and public humiliation that fell within psychological violence under RA 9262.
What the police officer must serve and pay
Despite affirming the conviction, the SC reduced the maximum prison term. The lower courts had sentenced the police officer to a minimum of two years, four months and one day and a maximum of 10 years and one day.
The High Court modified the sentence to two years, four months and one day as the minimum to nine years and four months as the maximum.
The police officer must also pay a P100,000 fine, P75,000 in moral damages and P75,000 in exemplary damages. The damages, but not the fine, carry legal interest of six percent a year from the finality of the decision until fully paid.
He was also ordered to undergo mandatory psychological counseling or psychiatric treatment. / KAL