MANILA, Philippines — In a significant ruling for survivors of sexual violence, the Supreme Court has affirmed that a complainant’s recantation does not automatically exonerate the accused, particularly in cases of domestic sexual abuse.
In a decision promulgated on October 6, 2025, but released on Thursday, February 12, 2026, the high court upheld the conviction of a father for the sexual abuse of his biological daughter, despite the daughter later claiming that her accusations were “fabricated.”
The Case Background
- The Incident: The abuse occurred in 2017 involving a then-teenage daughter and her father.
- Initial Conviction: In 2020, a regional trial court found the father guilty of rape.
- The Turnaround: Following the conviction, the daughter executed a recantation, stating she wanted to “help her father and for everyone to have peace,” and claimed she had not realized the gravity of her initial accusations.
- Appellate Ruling: The Court of Appeals (CA) later downgraded the crime from rape to lascivious conduct but maintained the conviction.
The Supreme Court’s Ruling The tribunal, in a decision penned by Associate Justice Antonio Kho Jr., gave no weight to the victim’s retraction.
- Jurisprudence on Recantations: The Court noted that testimonies solemnly given in court should not be disregarded lightly. It stated that “recantations are viewed with suspicion and reservation,” as they are often unreliable and prone to further repudiation.
- Trauma as Evidence: The high court pointed to trial records showing the daughter wept “uncontrollably” during her original testimony, which the court viewed as a genuine indication of the trauma she suffered.
- Cautious Scrutiny: Justice Kho emphasized that a cautious treatment of recanted statements is especially necessary in sexual abuse cases, where victims may face family pressure or emotional guilt for prosecuting a relative.
Penalties and Damages While the crime was downgraded to lascivious conduct, the Supreme Court ruled that the sexual abuse was sufficiently proven. The father was sentenced to serve up to 40 years in prison and ordered to pay P225,000 in damages to his daughter.
The ruling reinforces the legal standard that once a witness’s credibility is established during a trial, a subsequent change of heart—often influenced by external factors—is not enough to overturn a finding of guilt without “compelling reasons.” The decision is seen as a landmark in protecting vulnerable complainants from being pressured into withdrawing valid criminal charges.