An energy-based a posteriori error bound is proposed for the physics-informed neural network solutions of elasticity problems. An admissible displacement-stress solution pair is obtained from a mixed form of physics-informed neural networks, and the proposed error bound is formulated as the constitutive relation error defined by the solution pair. Such an error estimator provides an upper bound of the global error of neural network discretization. The bounding property, as well as the asymptotic behavior of the physics-informed neural network solutions, are studied in a demonstrating example.