People of the Philippines vs. Marivic Genosa, G.R. No. 135981

The Supreme Court stated that the battered woman syndrome is characterized by the "cycle of violence" which has three phases: 

1. The tension-building phase
2. The acute battering incident
3. The tranquil, loving (or, at least, nonviolent) phase

In order to satisfy the requisites for a valid self defense, the Supreme Court elaborated on three main points:

1. Each of the phases of the cycle of violence must be proven to have characterized at least two battering episodes between the appellant and her intimate partner.
2. The final acute battering episode preceding the killing of the batterer must have produced in the battered person's mind an actual fear of an imminent harm from her batterer and an honest belief that she needed to use force in order to save her life.
3. At the time of the killing, the batterer must have posed probable — not necessarily immediate and actual — grave harm to the accused, based on the history of violence perpetrated by the former against the latter.