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In Garcia vs. Drilon, G.R. No. 179267, 25 June 2013, the Supreme Court ruled regarding VAWC:
Arguably therefore, mistresses can now be charged with VAWC along with the husband under the principle of conspiracy.There is likewise no merit to the contention that R.A. 9262 singles out
the husband or father as the culprit. As defined above, VAWC may likewise
be committed “against a woman with whom the person has or had a sexual
or dating relationship.” Clearly, the use of the gender-neutral word “person”
who has or had a sexual or dating relationship with the woman encompasses
even lesbian relationships. Moreover, while the law provides that the
offender be related or connected to the victim by marriage, former marriage,
or a sexual or dating relationship, it does not preclude the application of the
principle of conspiracy under the Revised Penal Code (RPC).
