G.R. No. 140604; March 6, 2002
DR. RICO S. JACUTIN, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.

FACTS

Petitioner Dr. Rico Jacutin, the City Health Officer of Cagayan de Oro, was charged with Sexual Harassment under R.A. 7877. The Information alleged that on December 1, 1995, he demanded sexual favors from complainant Juliet Q. Yee, a 22-year-old nursing graduate seeking employment, as a condition for her employment in a family planning project. During the trial, Yee testified that under the guise of a job interview and a “research” program, Jacutin, after ensuring they were alone, asked intrusive personal questions, invited her to go bowling, and during the car ride, proceeded to pull down her pants and fondle her. She resisted, and he later gave her P300.00. The incident caused her severe emotional distress, leading to a suicide attempt and subsequent psychological counseling.
Petitioner denied the accusations, presenting an alibi that he was attending a medical conference in Manila on the date in question. He presented a logbook and testimonies to support his claim of being elsewhere. The Sandiganbayan found the complainant’s testimony credible, convicted Jacutin, and sentenced him to imprisonment, a fine, and damages.

ISSUE

Whether the Sandiganbayan erred in convicting petitioner of sexual harassment despite his defense of alibi and in its award of damages.

RULING

The Supreme Court affirmed the conviction. On the factual findings, the Court upheld the Sandiganbayan’s assessment of witness credibility, emphasizing that it is the trial court that has the direct opportunity to observe witness demeanor. The Court found no cogent reason to overturn these findings, noting that the complainant’s detailed and consistent narration of the sexually abusive acts, coupled with her subsequent traumatic reaction, lent credence to her account. Petitioner’s alibi was correctly rejected for being weak and not physically impossible, as the evidence showed the logbook supporting his presence at a conference was unreliable and entries were not made by the alleged attendees themselves.
On the legal sufficiency, the acts described—the demand for sexual favors as a condition for employment, accomplished through moral ascendancy and abuse of position—clearly constitute sexual harassment under R.A. 7877. The Court, however, modified the damages awarded. It reduced the moral damages to P30,000.00, holding that such awards must reasonably approximate the injury and not be punitive, and awarded P20,000.00 as exemplary damages to serve as a deterrent. The penalty of six months imprisonment and a P20,000 fine was sustained.