There is no crime of “simple rape” when a man had sexual intercourse with a woman through force, threat, or intimidation.
Thus, the Supreme Court (SC) declared that the crime of rape must never be trivialized as “simple,” least of all in the official nomenclature adopted in judicial decisions.
In a decision written by Associate Justice Henri Jean Paul B. Inting, the SC explained that rape was originally classified as crime against chastity under Article 335 of the Revised Penal Code.
However, with the enactment in 1997 of Republic Act No. 8353, the Anti-Rape Law, rape was reclassified as a crime against persons.
The legislative reclassification “affirms that rape is a serious crime that directly inflicts harm and trauma -- both physical and psychological --upon the victim.”
“After all, there is nothing ‘simple’ about rape and referring to it in such a manner downplays its severity and desensitizes the public to the harm it inflicts,” the SC clarified.
With its clarification, the SC affirmed the conviction of a man who raped a 13-year-old girl. Also affirmed was his jail term of a maximum of 40 years.
Both the regional trial court (RTC) and the Court of Appeals (CA) found the man guilty of “simple rape.” The man appealed his conviction before the SC. His appeal was dismissed.
The dispositive portion of the SC decision which was made public last Dec. 18:
“Accordingly, the Appeal is dismissed. The Decision dated Feb. 22, 2021, of the Court of Appeals in CA-G.R. CR-H.C. No. 03486 is affirmed. Accused-appellant XXX:257662 is found guilty of Rape. He is sentenced to suffer the penalty of reclusion perpetua and ordered to pay AAA (victim) P75,000 as civil indemnity, P75,000 as moral damages, and P75,000 as exemplary damages. The amounts shall earn interest at the rate of six percent per annum from the date of the finality of this Decision until fully paid.
“The Department of Social Welfare and Development is directed to refer AAA to the appropriate rape crisis center for the necessary assistance to be rendered to the victim and her family, in line with Republic Act No. 8505, the Rape Victim Assistance and Protection Act of 1998."