The Supreme Court 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.

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 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, which had upheld a lower court's conviction.

"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 Court 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.

Background of the case

The police officer and the teacher entered into a romantic relationship in 2019. The teacher learned she was pregnant in April 2020, and on May 28, both families met and agreed that the couple should marry.

The couple planned to go to the Local Civil Registrar 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 Supreme Court'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, asking to set another date. The couple eventually filed their marriage license application on June 11, 2020, but the next day, the woman learned the officer had withdrawn it. The LCR told her that the officer had said she knew about the withdrawal and that his family and friends did not favor the marriage.

An LCR employee testified that the officer returned after the application was processed and retrieved the documents, saying the marriage would not proceed.

A Municipal Social Welfare and Development Office employee who assessed the teacher testified that she was shaking and emotionally distraught, recommending a psychiatric evaluation and stating she 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 convicted the police officer on Dec. 4, 2023, of violating Section 5(i) of RA 9262, and the Court of Appeals affirmed the conviction on April 30, 2025. The CA cited the emotional anguish and stress suffered by the woman that led to the death of her baby.

The police officer argued that he should not be convicted because a breach of a promise to marry is not an actionable wrong, and he denied deliberately withdrawing the marriage application, saying he had only retrieved his birth certificate. The Court of Appeals rejected those arguments, finding that the unexplained withdrawal was the means by which the woman suffered emotional and mental anguish, and noting that he was not punished for failing to marry her. The CA also noted that the officer married another woman only months after the marriage application was withdrawn.

The Supreme Court's ruling

The Supreme Court 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. The Court found that prosecutors established that the officer and the teacher had such a relationship and that he withdrew the marriage license application without notice after a commitment made in the presence of their families. The withdrawal, the Court held, caused emotional anguish supported by the teacher's testimony and the assessments by the social welfare employee and psychometrician.

The Court said the officer's "willful" withdrawal of the marriage license, despite knowing the teacher was pregnant and had already announced their planned marriage, amounted to emotional manipulation and public humiliation falling within psychological violence under RA 9262.

The Court rejected the officer's claim that the law was improperly expanded. "The law is a protective statute; where an act — even one involving marriage applications — is used as a tool to inflict psychological trauma on a woman in a dating or sexual relationship, the law must be interpreted to hold the offender liable," the Court stated. "The RTC and the CA did not penalize the petitioner for the breach of promise to marry itself. Section 5(i) of RA 9262 specifically penalizes acts that cause mental or emotional suffering."

The Court also said the officer's arguments were laced with questions of fact and attempted to circumvent the rule by seeking a recalibration of the evidence already evaluated by the lower courts.

Modified penalty and damages

The Supreme Court modified the penalty imposed by the lower courts, reducing the maximum prison term from 10 years and one day to nine years and four months, with the minimum remaining two years, four months and one day. The officer must also pay a P100,000 fine, P75,000 in moral damages, and P75,000 in exemplary damages, with the damages carrying six percent interest per year from the finality of the decision until fully paid.

"Finally, the penalties of fine and the requirement of mandatory counseling are all proper and in accordance with the law," the Court ruled. "The same applies to the grant of moral and exemplary damages, as these awards are supported by factual basis and prevailing jurisprudence. However, the penalty of imprisonment must be modified."

The Court of Appeals had earlier ruled that the man "was not being penalized for the breach of promise to marry itself, but for the consequential effects of his actions that led to the teacher being humiliated and publicly ridiculed." The case is docketed as GR No. E-00648, with the decision written by Associate Justice Ramon Paul L. Hernando and posted on the Supreme Court website on August 17.