JANITO M. SEDENIO VS. PEOPLE OF THE PHILIPPINES
- G.R. Number: G.R. No. 276927
- Promulgated: 2026-01-19
Doctrine
## Facts of the Case Petitioner Janito M. Sedenio was charged with violating Section 5(h)(5) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004) for sending threatening and derogatory text messages to AAA, with whom he had a dating relationship, allegedly causing her alarm and substantial emotional or psychological distress. Sedenio and AAA had a two-year clandestine relationship while both were married to others. AAA managed his sugarcane plantation and contributed money entrusted to her by a lending institution, leading to issues with her employer. Their relationship soured after AAA learned Sedenio's wife was involved in the sugarcane harvest and revealed she was in a relationship with another man, YYY. Subsequently, between July and August 2012, Sedenio sent AAA numerous text messages containing threats, insults, and accusations. These messages included threats to burn YYY's belongings, humiliate AAA before creditors, expose intimate details, and mock the police’s arrival at AAA's home after Sedenio forcibly entered it. As a result, AAA claimed to have experienced mental anguish, sleepless nights, and a besmirched reputation. Sedenio admitted to sending "bad" text messages due to feeling hurt and being drunk, although he did not explicitly confirm the exact contents. The RTC found Sedenio guilty, sentencing him to imprisonment, a fine, and mandatory psychological counseling. The Court of Appeals affirmed the RTC’s decision. ## Issues 1. Did the Court of Appeals err in affirming Sedenio's conviction for violation of Section 5(h)(5) of Republic Act No. 9262 despite his arguments regarding improper authentication of text messages, lack of intent, and absence of psychological expert testimony? 2. Was the Information defective for not stating that Sedenio and AAA were no longer in a relationship at the time of its filing? ## Decision / Rationale **Issue 1:** The Court of Appeals did not err in affirming Sedenio's conviction for violation of Section 5(h)(5) of Republic Act No. 9262. * The Court found that the **text messages were sufficiently proven**. Under the **Rules on Electronic Evidence**, text messages can be proven by the testimony of a person who was a party to the conversation or has personal knowledge thereof. AAA, as the recipient and a party to the messages, testified to their content. Sedenio himself judicially admitted on cross-examination that he sent "humiliating and threatening words" to AAA from his mobile number because he felt hurt and was often drunk. This judicial admission removed the need for further authentication of the messages, as Sedenio cannot now retract it without showing palpable mistake. * The **elements of violence against women through harassment** under Section 5(h)(5) of Republic Act No. 9262 were all present: (1) Sedenio and AAA were in a dating relationship; (2) Sedenio committed a series of acts of harassment by sending numerous threatening and derogatory text messages; and (3) this harassment caused AAA alarm and substantial emotional or psychological distress. * Regarding the element of causing alarm or substantial emotional or psychological distress, the Court reiterated its ruling in **Araza v. People** that proof of the victim becoming psychologically ill is not required. The credible testimony of the victim is sufficient to establish this element, as their experiences are personal. AAA’s testimony detailing her mental anguish, sleepless nights, and besmirched reputation due to Sedenio's messages convincingly established this element. **Issue 2:** The Information was not defective for not stating that Sedenio and AAA were no longer in a relationship at the time of its filing. * The Court clarified that the first element of violence against women through harassment requires that the offender **has or had** a sexual or dating relationship with the offended woman. This means that a past relationship is sufficient to satisfy the element. The Information…