The term ‘victim-survivor’ was adopted by the Supreme Court (SC) when referring to persons who have experienced sexual violence.

In a decision written by Associate Justice Japar B. Dimaampao dated 24 February 2026, the SC’s Third Division affirmed a man’s conviction for the rape of a 12-year-old child.

In her testimony, the minor claimed that while everyone was asleep, the accused, who was the common-law spouse of her mother, dragged the child outside the residence of her uncle, raped her, pointed a knife at her, and threatened to kill her if she told anyone about the incident.

The victim told her uncle and aunt that the accused had been sexually abusing her since she was nine years old and that she did not report it earlier because she feared his threats.

Both the Regional Trial Court and the Court of Appeals found the accused guilty beyond reasonable doubt.

The conviction was affirmed by the SC, which found all elements of rape present and the accused positively identified as the rapist.

It also clarified its terminology in cases involving sexual violence. Instead of using the term “victim,” it adopted “victim-survivor” to acknowledge both the harm caused by the crime and the strength victims show in enduring and recovering from such violence.

“In lieu of the conventional victim when referring to individuals who have endured sexual violence, the term victim-survivor shall be
adopted.
This deliberate choice of words recognizes the harm and suffering inflicted while affirming the agency, resiliency, and continuing dignity of those who survive such violence.”

In addition to the penalty of reclusion perpetua, or up to 40 years in prison, the man was ordered to pay the victim-survivor PHP 450,000 in civil indemnity and damages.

As part of the government’s efforts to provide comprehensive support for victim-survivors, the SC also directed the Department of Social Welfare and Development to refer the minor to the proper rape crisis center for assistance.

This may include psychological counseling, medical and health services, measures to protect her privacy and safety, counseling and medical support for her family when needed, and programs to support her recovery.