Philippines

The appellant was found guilty by the Regional Trial Court and the Court of Appeals of raping his daughter AAA (who was eight at the time), and of acts of lasciviousness against his other daughter BBB (age nine at the time). On appeal, the appellant argued that his guilt was not established beyond reasonable doubt. He pointed to inconsistencies in witness testimonies about when his daughters told their aunt and others about the sexual abuse. The Supreme Court found that such inconsistencies are not related to the elements of the crime and do not diminish the credibility of the victim. Under Article 266-A of the Revised Penal Code, when the victim is under 12, the elements of rape are sexual congress with a woman by a man. Through the birth records, the age of the victim was clearly under 12, and through AAA’s testimony and physical examinations by the doctor, the element of sexual congress was met. The rule is that factual findings and evaluation of witnesses’ credibility made by the trial court should be respected unless it is shown that the trial court may have overlooked, misapprehended, or misapplied any fact or circumstance of weight and substance. The court refused to find AAA’s failure to tell others immediately as affecting her credibility. The court also reiterated that only the credible testimony of the offended party is necessary to establish the guilt of the accused. With respect to damages, the court overruled the lower courts, which had held that awarding damages would be a miscarriage of justice because the defendant-father was a compulsory heir to his daughters. It awarded BBB a total of P300,000 in civil indemnity, moral damages, and exemplary damages. The court awarded AAA P20,000 civil indemnity, P30,000 moral damages, and P20,000 exemplary damages because of the heinous nature of the crime. The court imposed sentences of reclus​ión perpetua (minimum of 30 years imprisonment) for the rape and 12 – 20 years imprisonment for the crime of lasciviousness.

The appellant was found guilty by the Regional Trial Court and the Court of Appeals of raping a 13-year-old girl by dragging her to a nearby farm, raping her and later threatening her with retaliation if she did not stay silent. The appellant appealed, pointing to inconsistencies in the number of times the victim testified as being raped and arguing that the prosecution was not able to prove his guilt beyond reasonable doubt. The Supreme Court affirmed the conviction. According to the court, the victim making inconsistent statements about the number of times the appellant raped her did not harm her credibility, given the fear and distress the victim suffered, and the frequency is also not an element of the crime. The required elements of rape under Article 266-A of the Revised Penal Code are: (1) offender had carnal knowledge of a woman and (2) he accomplished such act through force or intimidation, or when she was deprived of reason or unconscious, or when she was under 12 years of age, or demented. The medical examination and victim’s credible testimony meets the first element. The element of force or intimidation is met by the fact that the appellant dragged her and pushed her to the ground to abuse her. The appellant also intimidated her after the act. Thus, the required elements of rape under Article 266-A of the Revised Penal Code are met. The appellant’s alibi or denials were weak and uncorroborated.

The appellant was convicted of statutory rape of his daughter. The appellant claimed the rape had not happened because the daughter was not home, and that she was not a credible witness. The Supreme Court agreed with the findings and conclusion of the trial and appeals courts that rape was committed by the appellant. The Supreme Court noted that the testimony of a child-victim is to be given full weight and credence. The Supreme Court noted that respect for elders is deeply rooted in Filipino children and recognized by law such that there is a presumption that the child testified truthfully. Moreover, the concurrence of the age of the victim and her relationship to the offender warranted upgrades to the sentencing penalty.

The appellant was convicted of two counts of statutory rape. The appellant sought to overturn the conviction on the ground that the victim’s testimony was riddled with inconsistencies. The Supreme Court set forth the recognized rule that the “assessment of the credibility of witnesses is a domain best left to the trial court judge… and when his findings have been affirmed by the Court of Appeals, these are generally binding and conclusive upon this Court.” While there are recognized exceptions to this rule, the Supreme Court found no substantial reason to overturn the identical conclusions of the trial and appellate courts on the witnesses’ credibility and affirmed.

The respondent was found guilty of grave misconduct for sexually harassing his co-workers and was dismissed from Government service. The appeals court modified the ruling, finding him guilty of simple misconduct for which dismissal was not warranted. The Supreme Court reinstated the finding of grave misconduct, finding that the respondent’s actions were intentional, and since this was the third time he had been penalized for sexual harassment, dismissal was warranted.

The plaintiff successfully sought a Temporary Protection Order against her husband under Republic Act No. 9626 Against Women and Their Children. The husband appealed, claiming the Act to be unconstitutional and the order therefore invalid because the Act favored women over men as victims of violence and abuse to whom the State extends its protection. The Supreme Court held that the Act was valid, highlighting the unequal power relationship between women and men; that women are more likely than men to be victims of violence; and the widespread gender bias and prejudice against women, which all make for real differences justifying the law.

The appellant was convicted on two counts of marital rape. On appeal, the appellant argued that marital rape was not the equivalent of non-marital rape. This was the first documented case on marital rape to reach the Supreme Court. The Supreme Court rejected the appellant’s argument as essentially an attempt to revive old and now rejected standards that a husband could not be convicted of marital rape because of the “implied consent” of his wife. It found that under modern jurisprudence, the appellant’s argument would deny spouses equal protection under the constitution and that the elements and quantum of proof that support a moral certainty of guilt in rape cases should apply uniformly regardless of the legal relationship between the accused and his accuser.