Jurisprudence

While other victims immediately seek medical attention, some others choose to be silent
and will take time to muster the strength and courage to complaint against the
perpetrator. In fact, rape victims are, most of the time, advised to avail of psychiatric
treatments only to forget about their experiences. This is attributable to the fact that,
“there is no uniform behavior expected of victims after being raped. Different people
react differently to a given situation, and there is no standard form of behavioral
response when one is confronted with a strange or starling or frightful experience.” 1

In People vs. Freta 2 the Supreme Court ruled that “absence of external signs or
physical injuries does not negate the commission of rape since proof of injuries is not an
essential element of the crime.” In this case, private complainant lost consciousness
when being raped by the accused. It was impossible for her to resist or fight back, which
would explain the absence of such injuries. 3

Further, in People vs. Mendoza 4 the Supreme Court ruled that, “no decent and
sensible woman will publicly admit being a rape victim and thus run the risk of public
contempt – the dire consequence of a rape charge – unless, she is, in fact, a rape victim.”
This doctrine has been repeated all over in recent cases decided upon by the Supreme
Court in the cases of People vs. Batiancila,5 People vs. Tamayo, 6 People vs. Ubia,7 People
vs. Fontillas.8

This is because “when a woman says she was raped, she says in effect that all is
necessary to show that rape had been committed, and if her testimony meets the test
of credibility, the accused may be convicted on the basis thereof.

The peculiar nature of rape is that conviction or acquittal dependents almost

entirely upon the word of the private complainant because it is essentially committed in
relative isolation or even in secrecy, and it is usually only the victim who can testify of the
unconsented coitus. 9

Here, the private complaint filed by the private complainant consists of extremely
detailed narrations of how she was raped, which was stated above, and of how she was
psychically and emotionally tortured and abused by the accused, which make the same
very reliable. The private complainant’s Complaint-Affidavit (Exhibits “A” and “A-1”) and
the defense given the opportunity to cross-examine here.

1
People vs. Arraz, G.R. No. 183696, October 24, 2008
2
People vs. Freta, 406 Phil. 853, 862 (2001)
3
See Complainant-Affidavit, Page 22, Par. 34
4
People vs. Mendoza, 490 Phil. 737 (2005)
5
People vs. Batiancila, G.R. No. 174280, January 30, 2007
6
People vs. Tamayo, G.R. No. 137586, July 30, 2002
7
People vs. Ubia, G.R. No. 176349, July 10, 2007
8
People vs. Fontillas, G.R. No. 184177, December 15, 2010
9
People vs. Patentes, G.R. No. 190178, February 12, 2014