The María Clara doctrine, also known as the Woman's Honor doctrine, is a legal doctrine applied by

Philippine courts regarding cases that concerns abuse against women.

Etymology

The doctrine was named after María Clara from José Rizal's novel Noli Me Tángere. Clara is characterized
as reserved and shy and was later considered an "ideal" role model for women in Philippine culture.[1]

Legal history

The doctrine became a part of the Supreme Court of the Philippines' jurisprudence sometime in 1960
following the People v. Taño case. The high court through Justice Alejo Labrador has asserted a "well
known fact" that women, especially Filipinos "would not admit that they have been abused unless that
abuse had actually happened."[1] The court said that women's natural instict is to protect their
honor.[2]The case involved three armed robbers who the court found liable for taking turns in raping a
woman.[3]

About 58 years later since the doctrine entered the high court's jurisprudence, the Third Division of the
Supreme Court reverse a ruling on January 17, 2018 by a Davao court on two people convicted of rape.[1]
The 2018 decision was released in late-February.[4] The case involves an alleged rape that happened in
2009 and the two accused were sentenced of reclusión perpetua, or forty years of imprisonment, in 2012.
The decision was affirmed by the Court of Appeals in 2016. [5]

The court described the doctrine as causing a "travesty of justice" by putting the accused at an "unfair
disadvantage"[1], criticizing the doctrine for assuming that no Filipina woman of "decent repute" would
falsely claim that she was abused. It urged for the acceptance of the "realities of a woman’s dynamic role"
in Philippine society today so one can "evaluate the testimony of a private complainant of rape without
gender bias or cultural misconception". It also stated that the discrepancies in the alleged victim's
testimonies has casted doubt if the rape incident did happen or not.[3]

This has led to concerns and speculations that the high court has abandoned the doctrine.[1] The Gabriela
Women's Party condemned the decision which it viewed made the Maria Clara doctrine invalid saying the
ruling reversal will empower rapists and disagreed with the court's assessment of the societal status of
women.[4]

On February 21, 2018, Supreme Court's spokesperson, Theodore Te has clarified that it was not the case
since the high court can only abandon a doctrine only during a full session.[1]