HOW TO GET AWAY WITH RAPE:

THE MARRY YOUR RAPIST LAW

____________________

Term Paper

College of Law

University of Cebu-Banilad

Cebu City, Philippines

____________________

In Partial Fulfilment

of the Requirements for

Legal Research

Submitted by:

BEA PAMELA MIRAFLOR

Submitted to:

ATTY. CARLO VINCENT GIMENA

December 2018
 Table of Contents

INTRODUCTION ..................................................................................................................... 3
Rape defined .......................................................................................................................... 4
Marry Your Rapist/Forgiveness Clause ................................................................................. 5
BACKGROUND ....................................................................................................................... 7
History of Marry Your Rapist Law ........................................................................................ 8
DISCUSSION .......................................................................................................................... 13
How Marry Your Rapist Law Affects the Sanctity of Marriage .......................................... 13
Marry Your Rapist Law Only Favors the Rapist ................................................................. 14
Marry Your Rapist Law Condemns the Victims ................................................................. 15
Marry Your Rapist Law is Detrimental to the Child ........................................................... 16
CONCLUSION ........................................................................................................................ 18
The Marry Your Rapist Law Must be Repealed to Diminish Misogyny ............................. 18
and Sexism ........................................................................................................................... 18
RECOMMENDATION ........................................................................................................... 19
BIBLIOGRAPHY .................................................................................................................... 20
Books ................................................................................................................................... 20
Journal .................................................................................................................................. 20
Jurisprudence ....................................................................................................................... 20
Website ................................................................................................................................ 20
Newspaper ........................................................................................................................... 21

2
 INTRODUCTION

In every felony committed by an individual, criminal and/or civil liability is

attached. Criminal liability is defined as a responsibility that adheres to a person after

committing a felony. It is a debt incurred to the State where the criminal has to

indemnify through the imposition of the penalty by the State due to the social injury

caused. Social injury, as defined by Reyes (2017), is “produced by the disturbance and

alarm which are the outcome of the offense”.

To ensure the administration of justice, every person enjoys the presumption of

innocence until proven guilty. A person can only be held criminally liable for a certain

act or omission if the facts presented before the Court evidently prove that such person

is guilty of a felony. Article 4 of the Revised Penal Code enunciates that “criminal

liability shall be incurred by: (1) any person committing a felony (delito) although the

wrongful act done be different from that which he intended; and (2) any person

performing an act which would be an offense against persons or property, were it not

for the inherent impossibility of its accomplishment or on account of the employment

of inadequate or ineffectual means.”

Criminal liability can also be extinguished. Article 89 of the Revised Penal Code

pertains to the different modes of extinguishment of criminal liability, namely “(1)

death of the convict; (2) service of the sentence; (3) by amnesty (4) by absolute pardon;

(5) by prescription of the crime; (6) by prescription of the penalty; and by the marriage

of the offended woman, as provided in Article 344 of the Code.” Unfortunately, the last

provision results to the contrary of what the laws should entail--it perpetuates outright

injustice.

3
Rape defined

Rape is classified as a crime against persons under the Revised Penal Code.

Chapter 3, Title 8 of the Revised Penal Code comprehensively provides the definition

and penalties of Rape, pursuant to the Article 266-A of the Anti-Rape law which was

approved in September 30, 1997, to wit:

"Article 266-A. Rape: When And How Committed. - Rape is committed:

1) By a man who shall have carnal knowledge of a woman under any

Of the following circumstances:

a) Through force, threat, or intimidation;

b) When the offended party is deprived of reason or

otherwise unconscious;

c) By means of fraudulent machination or grave abuse of

authority; and

d) When the offended party is under twelve (12) years of age

or is demented, even though none of the circumstances

mentioned above be present.

2) By any person who, under any of the circumstances mentioned in

paragraph 1 hereof, shall commit an act of sexual assault by inserting

his penis into another person's mouth or anal orifice, or any instrument

or object, into the genital or anal orifice of another person.”

Senate Bill No. 1252 proposed by Senator Risa Hontiveros recommends some

amendments to the present Anti-Rape Law of 1997—including the amendment of the

definition of rape to declare the absence of consent as the essential requisite of rape.

4
Marry Your Rapist/Forgiveness Clause

The last mode of extinguishment has been controversial not only in the

Philippines, but also in other countries. The last provision—which is also known as the

forgiveness clause—completely exterminates the criminal liability of the rapist.

The purpose of such clause roots down to a psychological reasoning. Ro (2014)

published an article in and BBC posited that “[s]exual assault is a blow to beliefs about,

for instance, certain men (like a husband or a friend) being trustworthy. Some people

who are assaulted will reject this threat to their beliefs.”

Similarly, for the brain to counteract any other terrible or traumatic shock with

denial, it may be more comforting to believe that it wasn’t actually rape. The victims

almost always apologize on behalf of their assaulters and frequently minimize the

gravity of the assaults by interpreting them as cases of ‘miscommunication’ or ‘bad

sex’. Victims redirect the blame due to the several consequences of calling it rape –

which might range from gossip and feeling blamed to the loss of economic

opportunities, family disownment, and ostracism.

Several factors have been associated with increased feelings of distress and

increased use of avoidance coping strategies when dealing with an event such as rape.

These include (1) a lack of positive social support (Ingledew, Hardy, & Cooper, 1997;

Terry, 1991; Ullman, 1996; Vitaliano et al., 1990), receipt of negative social reactions

(Atkeson et al., 1982; Campbell, Ahrens, Sefl, Wasco, & Barnes, 2001; Davis et al.,

1991; Ullman, 1996; Ullman & Filipas, 2001), perceived lack of internal control over

stressors (Collins & Ffrench, 1998; Folkman, Lazarus, Dunkel-Schetter, DeLongis, &

Gruen, 1986; Ingledew et al., 1997; Terry, 1991), feelings of self-blame (Aldwin &

5
Revenson, 1987; Folkman et al., 1986), and multiple victimizations (Leitenberg,

Greenwald, & Cado, 1992).

Thus, it is not new for the victimized women to internalize the shame and

embarrassment, and blame themselves in anticipation of what skeptics will say. This

shame impedes recovery. However, this argument has loopholes that pins the

consequence more to the victim rather than the perpetrator. Rape, as it was previously

defined, emphasizes the lack of the essential requisite--consent. The victim did not

voluntarily participate in the consummation of the sexual deed as it was vitiated by

force. Hence, there is an absence of any justification as to why the victim should suffer

the harsh consequences of stigma notwithstanding the fact that she did not permit to the

act in the first place.

The Marry Your Rapist Law or Forgiveness Clause was basically rooted in the

profound belief of women’s subordination to men. However, what the law defends in

this case is not the physical and psychological integrity of women but rather man’s

property: a virgin daughter, sister or a future wife.

6
 BACKGROUND

Marry Your Rapist Law is prevalent in Latin and Arab countries, particularly

in Bahrain, Takijistan, Iran, Argentina, Brazil, Chile, Colombia, Ecuador, Guatemala,

Honduras, Nicaragua, Panama, Paraguay, the Dominican Republic, Venezuala, and

among others—Philippines.

Fortunately, as the zeal for Feminism becomes more compelling, more and more

countries start to recognize the loopholes of the forgiveness clause and decided to repeal

or abolish the said law.

The law has been present for at least 50 years. In 1999, Egypt was brave enough

to be the first one to take a step ahead and repeal the Marry Your Rapist Law. 15 years

later, Morocco followed the move—after the pivotal suicide of Amina Filali, a 16-year-

old girl who allegedly consumed rat poison after having being forced to marry her

rapist. Moroccan director Nadir Bouhmouch created a documentary about Amina’s

case, which garnered huge support and sympathy from all parts of the world, especially

through online movements such as the #RIPAmina. Thereafter in 2014, Morocco finally

repealed the forgiveness clause.

In Ethiopian Women’s Lawyer’s Association vs Ethiopa, 13-year-old Makea

was abducted twice and was forced to sign a marriage certificate on the second

abduction. Petitioners herein brought the case to the African Commission on Human

and People’s Rights where the Commission declared that “even though not expressly

listed under Article 5 of the Charter, rape is one of the most repugnant affronts to human

dignity and the range of dignity-related rights, such as security of the person and

7
integrity of the person, respectively guaranteed under Articles 6 and 4 of the Charter.”

Thereafter, Ethiopia repealed such clause.

In Lebanon, activists who are fighting for women’s rights administered several

protests for the abolition of the Marry Your Rapist Law reflected in Article 522 of the

Lebanese Penal Code. Some of these movements include online petitions, viral videos,

and a billboard showing a woman in a bloodied and torn gown with the caption "A

white dress doesn't cover up rape". Additionally, a non-governmental organization

named Abaad organized an art installation of 31 wedding dresses strung between the

palm trees of Beirut, Lebanon. Each wedding dress represents each day of the month in

which women could be subject to further abuse by attackers. The said organization also

conducted the protest called Dress 522 where several women were dressed with

wedding gowns made of bandages. With the collective efforts of fighting for women’s

rights, Lebanon’s parliamentary committee voted for the repeal of the forgiveness

clause, and was thereafter implemented.

Following the success of the aforementioned countries in fighting for the repeal

of such law, Tunisia, Palestine, Jordan also made a move. The Philippines still has a

long way to go before succeeding for the fight against the forgiveness clause, but it does

not mean that it will be impossible to achieve in the near future.

History of Marry Your Rapist Law

Contrary to popular belief, Marry Your Rapist law was influenced from

colonialism, not Islam (Osman, 2017). These countries which adopted the Marry Your

Rapist Law have one common denominator--they were colonized by the French Rule

or their subjugates. Mesbahi (2018) traced the roots of the Moroccan version of the

8
Marry Your Rapist Law. In her study, she stated that Moroccan Marry Your Rapist

Law, otherwise known as the Article 475 of the Moroccan criminal law, was copied

verbatim from the Napoleon Law, to wit:

Article 475 Morocco: Quiconque, sans violences, menaces ou fraudes,

enlève ou détourne, ou tente d’enlever ou de détourner, un mineur de moins de

dix-huit ans, est puni de l’emprisonnement d’un à cinq ans et d’une amende de

200 à 500 dirhams.

Lorsqu’une mineure nubile ainsi enlevée ou détournée a épousé son

ravisseur, celui-ci ne peut être poursuivi que sur la plainte des personnes ayant

qualité pour demander l’annulation du mariage et ne peut être condamné

qu’après que cette annulation du mariage a été prononcée.

Translation:

Anyone who, without violence, threats or fraud, abducts or distorts or

attempts to remove or diverts a minor under the age of eighteen years, shall be

punished by imprisonment of one to five years and a fine of 200 to 500 dirhams.

When a nubile minor thus abducted or diverted married his abductor, the

abductor can be prosecuted only on the complaint of the persons entitled to

request the annulment of the marriage and can not be condemned until after this

annulment of the marriage been pronounced.

Surprisingly, the word rape was not expressly provided for in the provision, but

the Moroccan courts construe the provision otherwise.

9
 The French law where Article 475 of the Moroccan Penal Law originated reads

as follows:

Celui qui, sans fraude ni violence, aura enlevé ou détourné, ou tenté d’enleverou

de détourner, un mineur de dix-huit ans, sera puni d’un emprisonnement de deux

à cinq ans et d’une amende de 500 F à 15000 F.

Lorsqu’une mineure ainsi enlevée ou détournée aura épousé son ravisseur,

celuici ne pourra être poursuivi que sur la plainte des personnes qui ont qualité

pour demander l’annulation du mariage et ne pourra être condamné qu’après

que cette annulation aura été prononcée.

Translation

A person who, without fraud or violence, has abducted or diverted or attempted

to abduct or misappropriate a minor under eighteen years old will be punished

by imprisonment of two to five years and a fine of 500 francs to 15000 F.

When a (female) minor thus abducted or diverted marries her abductor, the

abductor may be prosecuted only on the complaint of persons entitled to request

the annulment of the marriage and may be convicted only after the annulment

has been pronounced.

In Jordan, Marry Your Rapist Law is also reflected in Article 308 of the

Jordanian Penal Code. This law was adopted from the Ottoman Rule, but its origin is

even more distant – historically and geographically – as the Ottomans had imported it

from the French penal code (Osman, 2017). Jordan’s version of the Marry Your Rapist

Law states:

“[I] f a valid marriage is concluded between the perpetrator of one of the

10
 crimes provided in this chapter and the victim, the prosecution shall be

discontinued, and the execution of any sentence rendered against the

perpetrator shall be stayed. ”

According to figures from Jordan’s Ministry of Justice, 159 rapists avoided

punishment by marrying their victims between 2010-2013, and 300 rapes were recorded

annually on average during the same period – although activists point out the true figure

is likely to be chronically underreported in a country where extramarital sex is taboo.

Fortunately, in August 2017, the Jordan parliament also voted for the abolition

of the forgiveness clause (Osman, 2017).

France, where the Marry Your Rapist Law originated, also repealed the said

provision in 1998 (Osman, 2017).

Majority of the statutes in the Philippines were adopted from the Roman Law,

since the Philippines was under the rule of the Spaniards for more than 300 years. The

Philippine laws of today is a coalescence of the Roman Law, Filipino customs, common

law, and Mohammedan Law. The influence of the Roman Law is evident in the New

Civil Code, while the Revised Penal Code was a reproduction of the Spanish Penal

Code. For instance, the latin maxim ignorantia lexis non excusat, facit reum nisi mens

sit rea, and cessante ratione legis cessat ipsa lex are still compelling when it comes to

the Court’s decision making.

The Philippines classifies rape as a henious crime punishable by reclusion

perpetua to death. The original provision--which was copied from the Spanish Penal

Code--did not consider rape as a henious crime, but only as a private felony which

entails a light punishment. In a Philippine jurisprudence, the Court held that:

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 “The crimes of rape and abuse against chastity are provided for and

penalized in the same chapter of the Penal Code. . . . It is true that said chapter,

in its caption, does not give the same name to both crimes, but says "Rape and

Abuse Against Chastity," devoting the first article of said title, that is, article

438, to rape, and the second, namely, article 439, to abuse against chastity. It is

clear that the crime of rape, which has for an element, among others, the

intention to lie, cannot, nor should it, be confounded with abuse against chastity

where such intention is not an essential element. This circumstance, however,

does not prevent these two crimes from being of the same nature.”

Hence, Philippines’ version of the Marry Your Rapist Law was abrogated from

the Spanish Penal Code. It is fortunate that the Philippines later amended the rape laws

and classified rape as a heinous crime rather than a private crime.

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 DISCUSSION

How Marry Your Rapist Law Affects the Sanctity of Marriage

The Philippines acknowledges the sanctity of marriage as reflected in Article 1

of the Family Code which provides that “[m]arriage is a special contract of permanent

union between a man and a woman. . . .It is the foundation of the family and an

inviolable social institution. . . . “.

Article 3 of the same Code also declares the three formal requisites of marriage

namely: (1) authority of the solemnizing officer, (2) valid marriage license, and (3)

formal ceremony where the both parties appear before the solemnizing officer.

The same Code also declares the essential requisites: (1) legal capacity of the

contracting parties and (2) consent freely given. Absence of such formal and essential

requisites shall render the marriage void ab initio.

Freely given consent is a vital and essential requisite in contracts since contracts

carry with it certain responsibilities and liabilities. Ironically, the forgiveness clause

paves a way for a marriage wherein the rape victim may give her consent but does not

freely do so. As a result, the victims are forced to be liable of the responsibilities of

marriage despite their hesitance. This supposed to be inviolable contract becomes

challenged as perpetrators leverage it to instigate violence and trauma, which is the

complete opposite of what marriage is all about. Such sacred act must not be the source

of horrible and agonizing deeds. Should this continue, it “[will] diminish[es] the whole

concept of marriage to the only peripheral aspect of the sexual component.” (Ayman,

2019)

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Marry Your Rapist Law Only Favors the Rapist

The forgiveness clause is evidently unconstitutional since it violates the equal

protection clause and it favors the perpetrator only. Added to that, the law also provides

that the extinguishment of such criminal liability also extends to the codefendants.

The law provides that the marriage of the rapist to his victim must be valid and

must be done in good faith in order to extinguish his criminal liability. In People vs.

Santiago (1927), the accused raped the niece of his deceased wife and afterwards

fetched a protestant minister to officiate their marriage. Such marriage was void ab

initio since there was no consent from the parents of his niece as she was still a minor,

and that there was no bonafide intention of making her his wife.

In Costa Rica, “[i]ts laws exonerated any rapist who expressed an “intention” to

marry the woman he had raped, even if that woman did not accept his offer” (McDaniel,

2013). Fortunately, the Philippines does not consider a mere Intent to marry in

extinguishing the criminal liability of a person who committed rape. It was ruled in

People vs. Ramos (1959) that the accused is guilty of rape and his criminal liability

should not be extinguished since “a mere offer of marriage is not sufficient”.

Generally, rape is a criminal offense commonly defined as a forcible sexual

relations with a person against that person’s will. Hence, absence of consent is condition

sine qua non in crimes of rape. However, the Philippine Laws does not expressly state

so. In a press release last May 2017, Senator Risa Hontiveros suggested that the

Republic Act No. 8353 otherwise known as the Anti-Rape Law of 1997 should be

urgently amended as it “puts unjust burden on rape victims and is a far very from doing

justice to those aggrieved”. Among the suggested amendments of Hontiveros is to

14
“emphasize of the absence of consent as the essential element of the crime of rape.”

Sen. Hontiveros also recommended the repeal of the forgiveness clause. Sen.

Hontiveros believes that we cannot allow the proliferation of sexual harassment through

condoning and reinforcing sexism and misogyny.

The forgiveness clause only provides a last-ditch plea to the criminal for him to

escape from his criminal liability. In the Philippines, rape is considered as a heinous

crime punishable by reclusion perpetua. In other words, a person found guilty of rape

can be imprisoned from 20-40 years. However, due to the existence of the forgiveness

clause, rapists can easily evade from such afflictive penalty instead of facing the

consequences of his acts.

Marry Your Rapist Law Condemns the Victims

In Palestine, reports show that between 2011 and 2017 prosecution for rape has

been halted in 60 cases after the alleged rapist agreed to marry the victim. In 15 of these

cases the women later divorced these men.

The main purpose of the enactment of forgiveness clause in most countries is to

respect sexual contact. Majority of these countries “often interpret sexual relations

outside of marriage as a stain on a woman’s collective honor or integrity” (Sen, 2017).

Thus, if it is done outside of marriage, the only remedy available is to marry the girl to

avoid embarrassment. However, reality states otherwise. Marrying one’s rapist does not

protect the victim’s dignity—it saves the perpetrator from the embarrassment from his

heinous act.

15
 Marrying one’s rapist leaves a detrimental impact to the victim’s physical,

emotional, and mental state. Majority of these marriages end up in violence, divorce,

or worse—death by suicide of the victim.

Amina Filali is not the only victim who decided to end her life than to live her

life together with her rapist. Such cases of death is also prevalent in India and in other

countries where the Marry Your Rapist Law is still in their books.

In the Philippines, no reports show of suicide due to marrying one’s rapist at the

moment. However, this does not necessarily mean that it is not happening in the

country. There is still an undeniable probability that this may have occurred or is

happening only in silence.

The welfare and the mental state of the victim should be paramount to all. The

purpose of the Anti-Rape Law of 1997 and other related statutes is to protect the victim

from all the psychological trauma. However, the forgiveness clause seemingly

contradicts its purpose. Such clause only aggravates the situation as it allows the source

of the trauma to be part of the everyday life of the victim.

Marry Your Rapist Law is Detrimental to the Child

There is one last party that is almost always obliterated but is also enormously

affected by the forgiveness clause—the child. The mother faces yet another difficult

decision on how to raise the unexpected offspring. As a result, the child is delivered to

a foster care or worse—gets illegally aborted. In the Philippines, the rapist is compelled

to acknowledge and give support to the child. Article 345 of the Revised Penal Code

declares that “Persons guilty of crimes against chastity shall indemnify the offended

16
woman, acknowledge and support the offspring” provided that there be no legal

impediments on both parties. The main intent of such legislative act is to indemnify the

woman through acknowledging and the supporting the child as his own. However, such

indemnification is illogical. The parental rights of the rapist should not be compulsory.

The victim must have her own choice to compel the father to acknowledge the offspring

or not. Philippine laws which involve children are construed in favor of the general

welfare of the child. Above all, the mother knows what is best for her child therefore

she must not be deprived of the choice to terminate the parental rights of her rapist over

the offspring.

The equal protection clause provides every citizen with the fundamental right

to raise a family. Thus, courts are reluctant to terminate parental rights. However, such

a right is not absolute as it is limited to the welfare of the child. In Cervantes vs Fajardo,

the Court held that the minor who was less than one year old, should be reverted to the

custody of the adoptive parents since the biological parent is not only jobless but also

maintains an illicit relation with a married man. To compel the father to acknowledge

and support the child may incur moral impediments and create an undesired atmosphere

for the child. Thus, it is a well-founded argument that the role of the child’s preference

must also be considered when he comes of age as may be provided by law.

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 CONCLUSION

The Marry Your Rapist Law Must be Repealed to Diminish Misogyny

Law, as generally defined, is a just and obligatory rule of conduct prescribed by

a legitimate authority. Hence, a law must be repealed, revised, or amended if it fails to

deliver justice and equity--cessante ratione legis, cessat et ipsa lex. The main purpose

of the law is to give justice and respect the rights of every citizen. It is clear that the

Marry Your Rapist Law, or otherwise known as the Forgiveness Clause, ceases to

deliver justice as it violates the equal protection clause--it allows the rapist to evade

punishment while the victim suffers emotionally, mentally, and psychologically, and it

creates an undesired atmosphere for the child that may affect his/her welfare.

Under Article II, Section 14 of the 1987 Constitution, “the State recognizes the

role of women in nation-building and shall ensure the fundamental equality before the

law of women and men”. Further, under the same Article, the 1987 Constitution

declares that “the State values the dignity of every human person and guarantees full

respect for human“. Marry Your Rapist Law is thus unconstitutional since it posits that

a woman is merely a property that should be immediately given under the custody of a

man should there be a stain in her dignity--and in this case, a stain in her virginity. The

law simply strengthens a stimatized mentality where the dignity of a woman is limited

to her virginity, notwithstanding the psychological trauma and physical tormentation

she experienced with her assaulter. It evidently brings the men to the pedestal and pulls

the women back to the bottom despite the fact that it was not their choice to be raped.

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 It is still not too late for the Philippines to take a step forward and help make

the country a better place--a place where sexism and misogyny can no longer

proliferate.

RECOMMENDATION

To further enhance this study, the researcher recommend the following:

Finally, the researcher suggests to look for more factors which affect the
Marry Your Rapist Law in the Philippines.

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 BIBLIOGRAPHY
Books
Reyes, L. (2017). The Revised Penal Code Book I (19th ed.). Rex Bookstore.
Suarez, R. (2017). Introduction to Law (6th ed.). Manila: Rex Bookstore.

Journal
Mesbahi, Nima (2018). The Victimization of the “Muslim Woman”: The Case of
Amina Filali, Morocco. Journal of International Women's Studies, 19(3), 49-
59. Available at: http://vc.bridgew.edu/jiws/vol19/iss3/5
Littleton, H. L., Rhatigan, D. L., & Axsom, D. (2007). Unacknowledged Rape.
Journal of Aggression, Maltreatment & Trauma, 14(4), 57–74. doi:
10.1300/j146v14n04_04

Jurisprudence
People vs. Ramos, CA-G.R. 45741-R, July 29, 1959
People vs. Santiago, 51 Phil. 68, No. 27972 October 81, 1927

Website
Morgan McDaniel |, & International. (2013, May 2). From Morocco to Denmark:
Rape survivors around the world are forced to marry attackers. Retrieved
from http://www.womensmediacenter.com/women-under-siege/from-
morocco-to-denmark-rape-survivors-around-the-world-are-forced-to-marry.
Ayman, D., & Ayman, D. (n.d.). Women Survivors' worst nightmare: Forced
Marriage To Rapists. Retrieved from
https://wlahawogohokhra.com/8746/women-survivors-worst-nightmare-
forced-marriage-to-rapists/?lang=en.
Kanso, H. (2017, August 16). Lebanon abolishes 'marry your rapist' law, joining
other Arab states. Retrieved from https://www.reuters.com/article/us-
lebanon-rape-law/lebanon-abolishes-marry-your-rapist-law-joining-other-
arab-states-idUSKCN1AW1JR.
Act No. 3815, s. 1930: GOVPH. (1930, December 8). Retrieved from
https://www.officialgazette.gov.ph/1930/12/08/act-no-3815-s-1930/.
Pcw.gov.ph. (2019). Republic Act 8353 | Philippine Commission on Women.
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(2019). Retrieved 17 December 2019, from
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 Ro, C. (2019). Why most rape victims never acknowledge what happened.
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assault-victims-come-forward
475 : BREAK THE SILENCE. (2019). Retrieved 17 December 2019, from
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Makeda - Ethiopia. (2019). Retrieved 17 December 2019, from
https://www.equalitynow.org/makeda

Newspaper
Masigan, A. (2019, July 31). Philstar Global. Retrieved from
https://www.philstar.com/opinion/2019/07/31/1939322/rape-and-
misunderstood-law

Osman, H. (2017, August 2). Laws that allow rapists to marry their victims come
from colonialism, not Islam. The Independent. Retrieved from
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jordan-egypt-morocco-tunisia-came-from-french-colonial-times-
a7872556.html

McKernan, B. (2017, April 24). Lebanese women hang eerie wedding dresses
from Beirut seafront in rape law protest. The Independent. Retrieved from
https://www.independent.co.uk/news/world/middle-east/lebanon-women-
beirut-wedding-dress-rape-law-protest-seafront-corniche-water-abaad-
jean-oghassabian-a7698756.html

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