The Supreme Court's Second Division has affirmed the conviction of a traditional healer, known locally as an albularyo, sentencing him to up to 98 years in prison for four counts of sexual abuse against a 15-year-old patient. The ruling, penned by Associate Justice Jhosep Lopez and promulgated on February 19, 2026, rejected the defense's claims and established that fraudulent manipulation and deception completely void a victim's consent.
Landmark Ruling on Consent and Fraud
In its 20-page decision, the High Court clarified that full penile penetration is not required for a rape charge to be legally consummated. It ruled that all elements of rape and sexual assault under Article 266-A of the Revised Penal Code, as amended by Republic Act 8353 (the Anti-Rape Law of 1997), were proven beyond a reasonable doubt. The Court emphasized that when a traditional healer exploits a position of trust, influence, or spiritual authority to deceive a vulnerable minor into submitting to sexual acts under the false pretense of medical treatment, the submission is invalid.
Penalties and Damages
For two counts of rape through sexual intercourse, the SC imposed the penalty of double reclusion perpetua, carrying a maximum of 80 years. The healer was ordered to pay P75,000 as civil indemnity, P75,000 as moral damages, and P75,000 as exemplary damages for each of those counts. Additionally, for two counts of rape by sexual assault, he was sentenced to serve a prison term of four to nine years for each count, along with payments of P30,000 each for civil indemnity, moral damages, and exemplary damages. The total damages amount to P510,000.
Details of the Case
The case dates back to October 13, 2010, when the healer visited the home of a 15-year-old girl to treat an illness she believed was a hernia. Under the pretense of performing a medical healing session in a bedroom, he instructed the teenager to undress and subsequently raped her. He returned three days later for a follow-up, claiming it was the final session required to cure her, and raped her again. The teenager initially hid the assault out of fear but later confided in her sister after experiencing severe pain and bleeding. Her sister informed their grandmother, and together they reported the crime to the police.
A physical examination revealed healed hymenal lacerations consistent with sexual abuse. The trial court found the healer guilty of two counts of rape through sexual intercourse and two counts of rape by sexual assault. The Court of Appeals affirmed the conviction while modifying penalties and damages, leading the accused to appeal to the Supreme Court.
Court Rejects Defense Arguments
In its final review, the SC rejected the defense's claims of minor inconsistencies in testimonies and the assertion that the victim did not physically resist. The High Court found the teenager's testimony to be direct, candid, affirmative, and highly credible, corroborated by medical findings and her immediate physical distress. The justices ruled that rape is not exclusively committed through physical force or threats. They stated, "Contrary to the accused-appellant's claim, resistance is not necessary to establish rape, especially when the victim is manipulated... This Court ruled that when a person becomes a victim of fraudulent machination or manipulation, she does not have full control over her decisions."
The ruling added that passive submission under such circumstances does not equate to lawful consent because the victim's decision-making is completely compromised by fraud. The SC noted that the accused-appellant consciously took advantage of his standing in the community as an albularyo when he persistently portrayed his sexual acts as indispensable to her treatment and misled the victim into believing he had the capacity to cure her illness.
