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Gone were the days when a rape victim's testimony is sufficient to convict the

alleged rapist, solely because of the belief that a typical Filipina,

February 2009, the high court said "today, we simply cannot be stuck to the
Maria Clara stereotype of a demure and reserved Filipino woman" so as to
"evaluate the testimony of a private complainant of rape without gender bias or
cultural misconception."

The so-called ‘Maria Clara’ or “women’s honor” doctrine became part of


Philippine jurisprudence in the 1960’s in the case involving the conviction of
three armed robbers who toork turns raping Herminigilda Domingo.

The high court explained that the times have changed, and with it the Filipina.
"We, should stay away from such mindset and accept the realities of a
woman's dynamic role in society today; she who has over the years
transformed into a strong and confidently intelligent and beautiful person,
willing to fight for her rights.

"It is important to weed out these unnecessary notions because an accused


may be convicted solely on the testimony of the victim, provided of course,
that the testimony is credible, natural, convincing, and consistent with human
nature and the normal course of things," the high court said in its decision, as
it stressed that for a conviction of rape to rise, the victim's narration and
testimony must be believable beyond reasonable doubt," the SC said.

'Maria Clara' doctrine alone not sufficient for


rape conviction
VICTIM'S TESTIMONY NOT CREDIBLE

In the case of "AAA," the high court ruled that her testimony cast a doubt on
its very credibility and she was not telling the truth in her narration.

[T]he version in AAA's affidavit-complaint is remotely different from her court


testimony.

As for Racho, the high court said that "[s]ince we doubt AAA's account on how
she was raped by Amarela, we have to consider her testimony against Racho
under the same light.
Court held that the doctrine has put accused in rape cases at an unfair disadvantage and
creates a “travesty of justice.”

The SC said that for the Court to affirm a conviction of rape it should be based on
credible, natural, convincing testimony of the victim which should also be consistent with
human nature and not merely rely on the women’s honor doctrine.

“Although we put a premium on the factual findings of the trial court, especially when
they are affirmed by the appellate court, this rule is not absolute and admits exceptions,
such as when some facts or circumstances of weight and substance have been
overlooked, misapprehended and misinterpreted,” the SC declared.

“We, should stay away from such mindset and accept the realities of a woman’s dynamic role in society today;
she who has over the years transformed into a strong and confidently intelligent and beautiful person, willing
to fight for her rights. In this way, we can evaluate the testimony of a private complainant of rape without
gender bias or cultural misconception,” it said.

In a tweet, the Supreme Court (SC) spokesman said on February 21, “Only SC En Banc can abandon a
doctrine under Art. VIII, sec. 4(3). This case was decided by the 3rd Division.”