People of the Philippines v. Juvy D. Amarela and Junard G. Racho: Applying the Maria Clara Doctrine in the 21st Century
By: Ristel Mae B. Tagudando[1]
I. THE WOMEN’S HONOR DOCTRINE
The Maria Clara Doctrine or the Women’s Honor Doctrine became part of Philippine jurisprudence in the 1960 case of People v. Taño.[2] Based on Maria Clara’s character from Jose Rizal’s Noli Me Tangere, the doctrine provides the presumption that “women, especially Filipinos, would not admit that they have been abused unless that abuse had happened”.[3] This doctrine implies that the testimony of the alleged victim by itself may be sufficient to sustain a conviction.
II. SUMMARY OF THE CASE
In People v. Amarela, the plaintiff,AAA, was watching a beauty contest with her aunt when she went to the restroom to urinate. However, she was not able to reach the comfort room because Amarela stopped her along the way.
According to AAA, Amarela suddenly pulled her towards the daycare center and punched her in the abdomen, making her weak. Thereafter, Amarela undressed and put his penis inside AAA’s vagina. Three (3) men came to AAA’s rescue when she shouted for help, forcing Amarela to run away. However, she was brought to a hut by these persons, having bad intentions with her. Hence, she fled and ended up in the house of Godo Dumandan, who brought her first to the Racho residence because Dumandan thought her aunt was not at home. Dumandan stayed behind; that is why Racho was asked to bring AAA to her aunt’s house instead. However, instead, she was brought to a shanty. She was told to lie down, but she refused. Racho boxed her abdomen and placed himself on top of AAA. Racho then inserted his penis into AAA’s vagina. Thereafter, Racho left her. Thus, AAA went home alone and decided to leave home the following day. Eventually, AAA told her mother about what happened to her and reported the matter to the police.
The Regional Trial Court (RTC) rendered a decision finding the appellants guilty beyond reasonable doubt of the crime of rape as the plaintiff’s testimony positively identifying both appellants was clear, positive, and straightforward.
In appeal before the Court of Appeals (CA), the appellants argued that several circumstances cast doubt on the victim’s claim that she was raped. They alleged that her testimony does not conform to shared knowledge and ordinary human experience. Moreover, they pointed out that, although there were other witnesses, the only material testimony on record was that of the victim . However, the appellate court affirmed the trial court’s decision as it found no reason to reverse the factual findings of the court a quo.
For the Supreme Court (SC), it had no reason to deviate from the well-entrenched rule that in matters of credibility of witnesses, the assessment made by the trial court should be respected and given weight.
The Supreme Court reversed the judgment of conviction. First, AAA’s version of the story in her affidavit-complaint differs materially from her testimony in court. Second, AAA could not have easily identified Amarela because the crime scene was dark; she only saw him for the first time. Third, her testimony lacks material details on how she was brought under the stage against her will. Lastly, the medical findings do not corroborate physical injuries and are inconclusive of any signs of forced entry.
III. WEIGHING OF THE VICTIM’S TESTIMONY
The Supreme Court has long accorded the evaluations of testimonial evidence by trial courts great respect. One can expect that said determination is based on reasonable discretion as to opting for which testimony is acceptable and which witness is worthy of belief. However, although the factual findings of the trial court are given weight by the Court—most especially when affirmed by the appellate court—such rule is not absolute as, for instance, when some facts or circumstances of weight and substance have been overlooked, misapprehended, and misinterpreted.[4]
Presently, the Court follows specific guidelines when presented with the credibility of witnesses, to wit: giving the highest respect to the RTC’s evaluation of the testimony of the witnesses, considering its unique position in directly observing the demeanor of a witness on the stand. Second, absent any substantial reason that would justify the reversal of the RTC’s assessments and conclusions. The reviewing court is generally bound by the lower court’s findings, particularly when no significant facts and circumstances affecting the case’s outcome are shown to have been overlooked or disregarded. Lastly, such a rule is even more stringently applied if the CA concurred with the RTC. [5]
Applying the Maria Clara doctrine or the Women’s Honor doctrine—which often leads to cases being adjudged solely on the basis of the credibility of the victim – does not only put the accused at an unfair disadvantage but also results in a travesty of justice. It is not impossible for an assumed victim to merely fabricate stories of her abuse.
In the past, one can say that it is natural for a woman to be reluctant to disclose a sexual assault. This stereotype cannot be applied anymore as women have transformed over the years and have become more willing to speak up and fight for their rights . There is a need to veer away from such a notion and accept the realities of a woman’s dynamic role in society today.[6]
Leaving the aforementioned doctrine– given that the findings through evidence presented do not match the victim’s testimony – in the past is crucial because an accused must only 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. [7]
Furthermore, this rule was clarified in the recent case of People v. ZZZ. The Supreme Court relied on the victim’s testimony because the latter readily recognized and pointed to her violator. Unlike in People v. Amarela, the victim recounted the harrowing nights that tormented her for six years of living with the perpetrator, and the medico-legal examination corroborated the latter’s testimony. Hence, the SC found no compelling motive for the victim to lie. Furthermore, that after all, “no person, especially one of tender age, would ordinarily cry “rape” and subject oneself to the consequent rigors and embarrassments of medical examination and public trial, if not for the quest for rightful justice.[8]
IV. ERADICATING STEREOTYPES
The Supreme Court’s recent consideration and clarification as to the application of the Maria Clara doctrine in People v. Amarela would not only prevent corruption of justice on the part of the accused but eradicate gender bias and misconceptions in the society as well – especially on the part of women.
The old constructed perception of women anchored in the apparent attributes of Maria Clara – a pure soul, modest, self-effacing, long-suffering[9] – can no longer be applied absolutely today. Gone are the days when in cases of abuse, for a woman to be credible, she must be like Maria Clara; and when she does not fit the mold, there is a propensity of discrediting her as a witness, as exemplified in Tionloc[10]:
It would be unfair to convict a man of rape committed against a woman who, after giving him the impression through her unexplainable silence of her tacit consent and allowing him to have sexual contact with her, changed her mind in the middle and charged him with rape.
According to some women’s rights groups, the Court’s decision would open the floodgates to more incidents of rape, as this may embolden perpetrators to “abuse more women” confident that “courts will most likely dismiss rape cases. [11] The limitation of this ruling is already established in the ruling in the 2020 case of People v. ZZZ, wherein the Court still weighed the victim’s testimony based on factors such as her age, her recognition of the accused in open court, and other corroborative evidence.
Rather than completely disregarding a victim’s testimony, courts should distill it by doing away with outdated notions and stereotypes based purely on gender.
[1] UST Faculty of Civil Law, 2G, UST Law Review Understudy
[2] Citing People v. Taño, 109 Phil. 912(1960)
[3] “Maria Clara Doctrine in Rape Cases Revisited”. Buban and Lardizabal Law Offices. June 8, 2018.
[4] (People v. Amarela, 2018)
[5] (People v. Amarela, 2018)
[6] People v. Amarela, 2018
[7] People v. Zamoraga, 568 Phil. 132, 140 (2008); People v. Achas, 612 Phil. 652, 662 (2009); People v. Banig, 693 Phil. 303, 312 (2012); People v. Gahi, 727 Phil. 642, 657 (2014); People v. Pitala, G.R. No. 223561, 19 October 2016.
[8] (People v. ZZZ, 2020)
[9]Pons, J. S. (n.d.). Construction and deconstruction of Maria Clara: History of an imagined care-oriented model of gender in the Philippines. Academia.edu. https://www.academia.edu/24937445/Construction_and_deconstruction_of_Maria_Clara_History_of_an_imagined_care_oriented_model_of_gender_in_the_Philippines.
[10] 63 ATENEO L.J. 317 (2018)
[11] (The Philippine Star, 2018)
Cover Photo: Painting by Juan Luna- La Bulaqueña, 1985 and Puesta Del Sol, 1880’s.
