Summary
The Supreme Court’s Second Division affirmed the conviction of a traditional healer (albularyo), sentencing him to up to 98 years in prison for four counts of sexual abuse against a 15-year-old patient.
Associate Justice Jhosep Lopez penned the 20-page ruling, promulgated on February 19, 2026, which rejected the defense's claims and affirmed that fraudulent manipulation and deception completely void a victim's consent.
The High Court ordered the healer to pay a total of ₱510,000 in civil indemnity, moral damages, and exemplary damages for two counts of rape through sexual intercourse and two counts of rape by sexual assault.
A TRADITIONAL healer has been sentenced to up to 98 years in prison for raping a 15-year-old patient under the guise of medical treatment.
The decision penalizes a well-known community practitioner of folk medicine, locally known as an albularyo, for four counts of sexual abuse. Penning the 20-page ruling on behalf of the Supreme Court’s (SC) Second Division, Associate Justice Jhosep Lopez affirmed that traditional healers who exploit their positions of trust to deceive minors into sexual acts commit rape, even if the victim did not physically resist.
The ruling, promulgated on Feb. 19, 2026, resolves an appeal originating from lower courts. It establishes clear guidelines on how fraudulent manipulation invalidates a victim’s consent.
What’s rape
In its decison, the High Court clarified that full penile penetration is not required for a rape charge to be legally consummated. It also ruled that all elements of rape and sexual assault under Article 266-A of the Revised Penal Code, as amended by Republic Act 8353, or the Anti-Rape Law of 1997, were proven beyond a reasonable doubt.
For the two counts of rape through sexual intercourse, the SC meted out the penalty of double reclusion perpetua against the healer, which carries a a maximum of 80 years.
The High Court also ordered him to pay P75,000 as civil indemnity, P75,000 as moral damages and P75,000 as exemplary damages for each of those counts.
Adding a maximum of 18 years to his sentence, the traditional healer was sentenced to serve a prison term of four to nine years for each of the two counts of rape by sexual assault, along with payments of P30,000 each for civil indemnity, moral damages and exemplary damages.
Abuse under the guise of healing
The case dates back to Oct. 13, 2010, when the healer went to the house 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, the man instructed the teenager to undress. He later raped her.
The healer returned three days later for a follow-up check-up. He raped the girl again, claiming that it was the final session required to cure her.
Fearing the healer, the teenager initially hid the assault. She experienced severe physical pain and bleeding, prompting her to confide in her sister the following day. Her sister immediately informed their grandmother and together they accompanied the girl to the police station to report the crime.
A physical examination by doctors revealed healed hymenal lacerations that were consistent with sexual abuse. A trial court later found the healer guilty of two counts of rape through sexual intercourse and two counts of rape by sexual assault.
The Court of Appeals later affirmed the conviction while modifying the penalties and damages, leading the accused to appeal his case to the SC.
Deception voids consent
In its final review, the SC rejected the defense’s claims of minor inconsistencies in the testimonies and the assertion that the victim did not physically resist the acts. The High Court found the teenager’s testimony to be direct, candid, affirmative and highly credible, corroborated by the medical findings of tearing and the victim’s immediate physical distress.
The justices said rape is not exclusively committed through physical force or threats. When an albularyo 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, they ruled.
“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 SC said.
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 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 that he had the capacity to cure her illness,” the SC said. / KAL