Case Summary (G.R. No. 140604)
Respondent
People of the Philippines, represented by the prosecution in the Sandiganbayan.
Key Dates
• December 1, 1995 – Alleged incident of sexual harassment.
• July 22, 1996 – Filing of the accusatory Information.
• November 5, 1999 – Sandiganbayan conviction.
• November 10, 2003 – Supreme Court promulgation of decision.
Applicable Law
• Republic Act No. 7877 (Anti-Sexual Harassment Act of 1995), Sections 3 and 7.
• 1987 Constitution of the Philippines (due process, presumption of innocence).
Factual Background
Ms. Yee and her father, a boyhood friend of petitioner, sought employment assistance at the City Health Office. After preliminary meetings on November 28 and 29, 1995, petitioner offered her a research position in a family planning project. On December 1, 1995, under the guise of a physical examination, he:
• Demanded exposure of her private parts.
• Fondled her breast and inserted his hand into her underwear.
• Threatened confidentiality and later offered P300.
Ms. Yee suffered psychological trauma, diagnosed as post-traumatic stress by Dr. Merlita Adaza.
Procedural History
Petitioner pleaded not guilty. The Sandiganbayan found him guilty of sexual harassment under RA 7877, sentencing him to:
• Six months’ imprisonment.
• Fine of P20,000 (with subsidiary imprisonment).
• Indemnification of P300,000 moral and P200,000 exemplary damages.
Petitioner appealed, asserting:
I. RA 7877 is inapplicable.
II. Insufficient evidence and violation of due process.
Issues
- Applicability of RA 7877 to a public officer’s conduct in relation to official functions.
- Sufficiency of evidence and compliance with due process.
Application of RA 7877
Section 3 defines work-related sexual harassment as demanding sexual favors in employment contexts by any person with authority or moral ascendancy. Petitioner’s high position enabled him to solicit sexual favors as a condition for employment or research participation, meeting the statutory definition regardless of Ms. Yee’s later resistance.
Sufficiency of Evidence and Due Process
• Ms. Yee’s detailed testimony and expert psychological evidence established the molestation.
• Corroboration by other witnesses indicated a pattern of similar conduct.
• The Sandiganbayan properly evaluated credibility and rejected the alibi defense due to documentary inconsistencies.
• Factual findings by the trial court are conclusive absent clear error; the Supreme Court defers to the trial court’s assessment of deportment and witness reliability.
Damages and P
Case Syllabus (G.R. No. 140604)
Procedural History
- Accusatory Information filed on 22 July 1996 before the Sandiganbayan, Fourth Division, charging Dr. Rico S. Jacutin with Sexual Harassment under RA 7877.
- Petitioner pleaded not guilty; trial ensued with presentation of complainant and defense evidence.
- On 05 November 1999, the Sandiganbayan rendered judgment convicting petitioner of Sexual Harassment, sentencing him to six months’ imprisonment, P20,000 fine, and indemnities totaling P500,000 (P300,000 moral; P200,000 exemplary), plus costs.
- Petitioner elevated the case to the Supreme Court by way of petition for review on certiorari.
- G.R. No. 140604 was argued on 06 March 2002; decision promulgated on 10 November 2003.
Facts
- Complainant Juliet Q. Yee, 22-year-old BS Nursing graduate seeking employment, accompanied by her father (a childhood friend of petitioner) to the City Health Office in late November 1995.
- Petitioner, City Health Officer of Cagayan de Oro (salary grade 26), initially informed them of no vacancy in his office but promised to help.
- On 01 December 1995, petitioner offered Juliet a position in a family planning research project, subject to “physical examination” as part of research.
- Juliet’s father left upon petitioner’s suggestion that she answer more freely in private.
- Petitioner asked a series of personal questions (boyfriend status, virginity), then scheduled a follow-up “interview” after lunch.
- After lunch, efforts to secure a hospital post failed; petitioner renewed research offer, joked about physical contact (“hugging”), then invited Juliet bowling.
- At Borja Street, petitioner picked up Juliet in his car, drove to his home to change attire, and returned to the car.
- While driving, petitioner claimed to check her pulse, then examined her legs by lowering her pants, inserted his hand inside her panty toward her pubic hair, fondled her abdomen and breasts under the guise of research.
- Shocked, Juliet resisted, covered herself, and terminated the encounter; petitioner urged silence and gave her P300.
- Juliet