The Supreme Court of the Philippines has issued a landmark ruling that establishes clear legal guidelines for determining who owns or controls a social media account when its posts become the basis of a criminal case. This decision provides crucial guidance for prosecutors and courts in the digital age.
Conviction Upheld in Facebook Harassment Case
In the case of XXX v. People (G.R. No. 274842, October 22, 2025), the Supreme Court's First Division, through a decision penned by Associate Justice Ramon Paul L. Hernando, affirmed the conviction of a man identified as XXX for committing psychological violence against his former girlfriend, AAA. The conviction was under Section 5(i) of Republic Act No. 9262, the Anti-Violence Against Women and Their Children (Anti-VAWC) Act.
The court found that XXX's actions, which involved posting derogatory and insulting statements about AAA on Facebook, constituted public ridicule and caused her significant psychological harm. As a result, XXX was sentenced to up to eight years of imprisonment and ordered to pay a fine of P100,000. He was also mandated to undergo psychological counseling or psychiatric treatment.
The Story Behind the Social Media Posts
The court records detail a tumultuous relationship between XXX and AAA that lasted three years and resulted in a child. After AAA refused a marriage proposal due to ongoing problems, XXX allegedly assaulted her during a visit to see their daughter. Traumatized, AAA blocked XXX on all her social media accounts.
Years later, AAA's siblings received a private message on Facebook Messenger from an account they recognized as belonging to XXX. The message accused AAA of causing his mother's heart attack. The following day, AAA learned from a friend that the same account had made a public post in the Kapampangan language, calling her a "dirty woman," an animal, and threatening to punch her if seen. The post attracted insulting comments.
Fearing for her safety, AAA filed a case under the Anti-VAWC Act. During the trial, printouts of the Facebook post were presented as evidence. AAA testified that she had originally created the Facebook account for XXX, which he then used. XXX's own siblings testified that the account belonged to him and that they had received messages from it.
Supreme Court's Guideposts for Proving Account Ownership
Justice Hernando's decision emphasized that in cases relying on social media evidence, proving the elements of the crime is not enough. Courts must also consider the basic features of the platform, like Facebook. The Supreme Court laid down specific guideposts to determine who owns or controls an account:
- Claim of ownership or authorship of the posted content.
- Evidence that the accused accessed the account or composed the post.
- Information contained in the post that only the offender or a few people would know.
- Use of language or dialect commonly used by the offender.
- Records from internet service providers, telecom companies, or the social media site itself, including forensic analysis showing geolocation data linking the account to the offender.
- Previous actions or posts from the account that are similar in nature.
- Any other circumstance indicating the offender owned, had access to, and authored the post.
Applying these tests, the Supreme Court found overwhelming proof that XXX was behind the harassing post. The account bore his full name, and the profile picture showed him with a child from his new live-in partner. The messages to AAA's siblings over several years and the post's content—which referenced AAA blocking him—were details only XXX would likely know.
The High Court upheld the rulings of the Family Court and the Court of Appeals, which had rejected XXX's defense that someone else used his photo and that he was working as a restaurant waiter at the time of the post.
This ruling sets a critical precedent for future cases where digital evidence is central, providing a much-needed framework for justice in the realm of social media.
