People vs. Matrimonio, G.R. Nos. 82223-24 (Philippines)

A 14-year-old girl was raped by her father, who employed threats that he will kill her, her mother, her and siblings. The accused was convicted by the trial court. In upholding the conviction, the Supreme Court cited jurisprudence to the effect that when a woman testifies that she has been raped, she says in effect, all that is necessary to constitute the commission of the crime. The court characterized the testimony of the victim, as making "public a painful and humiliating secret which others would have simply kept to themselves forever, jeopardized her chances of marriage or foreclosed the possibility of a blissful married life, as her husband may not understand the excruciatingly painful experience which would haunt her. She further realized too well that her denunciations against her father would only bring down on her and her family shame and humiliation." While these considerations strengthened the court's conviction that the victim was telling the truth, it highlights negative community attitude toward rape victims which may discourage them from coming forward.