A.

Statement of the problem

This study aimed to Enlightenment the readers about Death Penalty

Particularly, It is deliberate to answer the following questions

1. What are the proposed conditions and crimes which will result for a convict to be

given a death penalty?

2. Why is it that other Filipinos are so opposed on the restoration of the Death

Penalty in the Philippines?

3. How should the government act to further decrease the crime rate of the

Philippines and to avoid the restoration of the Death Penalty?

The Detterent Theory suppose that the punishment is specified at the best towards for

no reason in particular. Thus, other recommend suchlike evil should be returned for evil

in the absence of taking into examination any outcome. There are two theories in

whichever this theory can be split more distany. That are particular prevention and

widespread prevention In specific deterrence, punishment is planned such that other

can teach the criminals. Thus, this can improve the criminals that are put through this

theory. Also it is continued that the punishment refines the criminals. This is done by

construct a fear that the punishment will be sustained. While a general deterrence is

planned to avoid future misdeed. So, this is done by making a sample of each accused.

Thus, it terrifies the subject to not do what the appellant did.

C. Background of Case study

Leo Pilo Echegaray (11 July 1960 – 5 February 1999) was the first Filipino to be

meted the death penalty after its reinstatement in the Philippines in 1993, some 23

years after the last judicial execution was carried out. His death sparked national

debate over the legality and morality of the death penalty, which was later suspended

on 15 April 2006.

[G.R. No. 117472.  June 25, 1996]

PILO, accused-appellant.

DECISION

PER CURIAM:

These are the pertinent facts of the case as summarized by the Solicitor-General in his

brief:

"This is a case of rape by the father of his ten-year old daughter.

Complainant RODESSA ECHEGARAY is a ten-year old girl and a fifth-grader, born on

September 11, 1983.  Rodessa is the eldest of five siblings.  She has three brothers

aged 6, 5 and 2, respectively, and a 3-month old baby sister.  Her parents are Rosalie

and Leo Echegaray, the latter being the accused-appellant himself.  The victim lives

with her family in a small house located at No. 199 Fernandez St., Barangay San

Antonio, San Francisco Del Monte, Quezon City (pp. 5-9, Aug. 9, 1994, TSN).

Sometime in the afternoon of April 1994, while Rodessa was looking after her three

brothers in their house as her mother attended a gambling session in another place,

she heard her father, the accused-appellant in this case, order her brothers to go out of

the house (pp. 10-11, ibid.).  As soon as her brothers left, accused-appellant Leo

Echegaray approached Rodessa and suddenly dragged her inside the room (p.

12, ibid).  Before she could question the appellant, the latter immediately removed her

panty and made her lie on the floor (p. 13, ibid.).  Thereafter, appellant likewise

removed his underwear and immediately placed himself on top of

causing her to suffer intense pain (pp. 14-15, ibid.).  While appellant was pumping on

her, he even uttered: 'Masarap ba, masarap ba?' and to which Rodessa

answered:  'Tama na Papa, masakit' (p. 16, ibid.).  Rodessa's plea proved futile as

appellant continued with his act.  After satisfying his bestial instinct, appellant

threatened to kill her mother if she would divulge what had happened.  Scared that her

mother would be killed by appellant, Rodessa kept to herself the ordeal she

suffered.  She was very afraid of appellant because the latter, most of the time, was

high on drugs (pp. 17-18, ibid.).  The same sexual assault happened up to the fifth time

and this usually took place when her mother was out of the house (p.

19, ibid.).  However, after the fifth time, Rodessa decided to inform her grandmother,

Asuncion Rivera, who in turn told Rosalie, Rodessa's mother.  Rodessa and her mother

proceeded to the Barangay Captain where Rodessa confided the sexual assaults she

suffered.  Thereafter, Rodessa was brought to the precinct where she executed an

affidavit (p. 21, ibid.).  From there, she was accompanied to the Philippine National

Police Crime Laboratory for medical examination (p. 22, ibid.).

Rodessa testified that the said sexual assaults happened only during the time when her

mother was pregnant.  Rodessa added that at first, her mother was on her

side.  However, when appellant was detained, her mother kept on telling her: 'Kawawa

naman ang Tatay mo, nakakulong' (pp. 39-40, ibid.).

When Rodessa was examined by the medico-legal officer in the person of Dra. Ma.

Cristina B. Preyna,[3] the complainant was described as physically on a non-virgin state,

Aug. 22,1995, pp. 8-9)."[4]

On the other hand, the accused-appellant's brief presents a different story:

"x x x the defense presented its first witness, Rosalie Echegaray.  She asserted that the

RAPE charge against the accused was only the figment of her mother's dirty

mind.  That her daughter's complaint was forced upon her by her grandma and the

answers in the sworn statement of Rodessa were coached.  That the accusation of

RAPE was motivated by Rodessa's grandmother's greed over the lot situated at the

Madrigal Estate-NHA Project, Barangay San Antonio, San Francisco del Monte, Quezon

City, which her grandmother's paramour, Conrado Alfonso gave to the accused in order

to persuade the latter to admit that Rodessa executed an affidavit of desistance after it

turned out that her complaint of attempted homicide was substituted with the crime of

RAPE at the instance of her mother.  That when her mother came to know about the

affidavit of desistance, she placed her granddaughter under the custody of the

Barangay Captain.  That her mother was never a real mother to her.

She stated that her complaint against accused was for attempted homicide as her

husband poured alcohol on her body and attempted to burn her.  She identified the

certification issued by the NHA and Tag No. 87-0393 (Exh. 2).  That the Certification

based on the Masterlist (Exh. 3) indicates that the property is co-owned by accused and

Conrado Alfonso.  That Rodessa is her daughter sired by Conrado Alfonso, the latter

being the paramour of her mother.  That Conrado Alfonso waived his right and

participation over the lot in favor of the accused in consideration of the latter's
accepting the fact that he is the father of Rodessa to simulate the love triangle and to

conceal the nauseating sex orgies from Conrado Alfonso's real Wife.

Accused testified in his behalf and stated that the grandmother of the complainant has

a very strong motive in implicating him to the crime of RAPE since she was interested to

become the sole owner of a property awarded to her live-in partner by the Madrigal

Estate-NHA Project.  That he could not have committed the imputed crime because he

considers Rodessa as his own daughter.  That he is a painter-contractor and on the

date of the alleged commission of the crime, he was painting the house of one Divina

Ang of Barangay Vitalis, Parañaque, Metro Manila (Exh 4).  The travel time between his

work place to his residence is three (3) hours considering the condition of traffic.  That

the painting contract is evidenced by a document denominated 'Contract of Services'

duly accomplished (see submarkings of Exh. 4).  He asserted that he has a big sexual

organ which when used to a girl 11 years old like Rodessa, the said female organ will

be 'mawawarak.' That it is abnormal to report the imputed commission of the crime to

the grandmother of the victim.

Accused further stated that her(sic) mother-in-law trumped-up a charge of drug

pushing earlier and he pleaded guilty to a lesser offense of using drugs.  The decretal

portion of the judgment of conviction ordering the accused to be confined at the

Bicutan Rehabilitation Center irked the grandmother of Rodessa because it was her

wish that accused should be meted the death penalty.

Accused remain steadfast in his testimony perorating the strong motive of Rodessa's

grandmother in implicating him in this heinous crime because of her greed to become
the sole owner of that piece of property at the National Housing Authority-Madrigal

Project, situated at San Francisco del Monte, Quezon City, notwithstanding rigid cross-

examination.  He asserted that the imputed offense is far from his mind considering

that he treated Rodessa as his own daughter.  He categorically testified that he was in

his painting job site on the date and time of the alleged commission of the crime.

Mrs. Punzalan was presented as third defense witness.  She said that she is the laundry

woman and part time baby sitter of the family of accused.  That at one time, she saw

Rodessa reading sex books and the Bulgar newspaper.  That while hanging washed

clothes on the vacant lot she saw Rodessa masturbating by tinkering her private

parts.  The masturbation took sometime.

This sexual fling of Rodessa were corroborated by Silvestra Echegaray, the fourth and

last witness for the defense.  She stated that she tried hard to correct the flirting

tendency of Rodessa and that she scolded her when she saw Rodessa viewing an X-

rated tape.  Rodessa according to her was fond of going with friends of ill-repute.  That

(sic) she corroborated the testimony of Mrs Punzalan by stating that she herself saw

Rodessa masturbating inside the room of her house."[5]

In finding the accused-appellant guilty beyond reasonable doubt of the crime of rape,

the lower court dismissed the defense of alibi and lent credence to the straightforward

testimony of the ten-year old victim to whom no ill motive to testify falsely against

accused-appellant can be attributed.  The lower court likewise regarded as

inconsequential the defense of the accused-appellant that the extraordinary size of his
penis could not have insinuated itself into the victim's vagina and that the accused is

not the real father of the said victim.

The accused-appellant now reiterates his position in his attempt to seek a reversal of

the lower court's verdict through the following assignment of errors:

“1.  THE LOWER COURT FAILED TO APPRECIATE THE SINISTER MOTIVE OF PRIVATE

COMPLAINANT'S GRANDMOTHER THAT PRECIPITATED THE FILING OF THE CHARGE

OF RAPE, HENCE IT ERRED IN HOLDING ACCUSED GUILTY AS CHARGED.

2.  THE COURT BELOW OVERLOOKED THE FACT THAT THE HEALED LACERATIONS AT

3 AND 7 O'CLOCK COULD NOT HAVE BEEN DUE TO THE PUMPING OF THE PENIS OF

ACCUSED TO THE VAGINA OF PRIVATE COMPLAINANT, HENCE IT ERRED IN HOLDING

THAT ACCUSED COMMITTED THE CRIME CHARGED, NOTWITHSTANDING VEHEMENT

DENIAL.

3.  THE COURT A QUO WHIMSICALLY IGNORED THE DEFENSE OF ALIBI THAT

ACCUSED WAS IN PARAÑAQUE ON THE DATE AND TIME OF THE IMPUTED CRIME

HENCE, IT ERRED IN HOLDING THAT ALIBI IS NOT SUSTAINABLE IN THE CASE AT

BAR."[6]

Considering that a rape charge, in the light of the reimposition of the death penalty,

requires a thorough and judicious examination of the circumstances relating thereto,

this Court remains guided by the following principles in evaluating evidence in cases of

this nature:  (a) An accusation for rape can be made with facility; it is difficult to prove

but more difficult for the accused though innocent to disprove; (b) In view of the
intrinsic nature of the crime of rape where only two persons are involved, the testimony

of the complainant must be scrutinized with extreme caution; and (c) The evidence for

the prosecution must stand and fall on its own merits, and cannot be allowed to draw

strength from the weakness of the evidence for the defense." [7]

Anent the first assigned error, no amount of persuasion can convince this Court to tilt

the scales of justice in favor of the accused-appellant notwithstanding that he cries foul

insisting that the rape charge was merely concocted and strongly motivated by greed

over a certain lot situated at the NHA-Madrigal Estate Housing Project, Barangay San

Antonio, San Francisco del Monte, Quezon City.  The accused-appellant theorizes that

prosecution witness Asuncion Rivera, the maternal grandmother of the victim Rodessa,

concocted the charge of rape so that, in the event that the accused-appellant shall be

meted out a death sentence, title to the lot will be consolidated in her favor.  Indeed,

the lot in question is co-owned by the accused-appellant and Conrado Alfonso, the live-

in partner of Asuncion Rivera, according to the records of the National Housing

Authority (Exh. "3").  The accused-appellant would want us to believe that the rape

charge was fabricated by Asuncion Rivera in order to eliminate the accused-appellant

from being a co-owner.  So, the live-in partners would have the property for their own.

[8]

We believe, as did the Solicitor-General, that no grandmother would be so callous as to

instigate her 10-year old granddaughter to file a rape case against her own father

simply on account of her alleged interest over the disputed lot. [9]
It is a well-entrenched jurisprudential rule that the testimony of a rape victim is credible

where she has no motive to testify against the accused. [10]

We find no flaws material enough to discredit the testimony of the ten-year old Rodessa

which the trial court found convincing enough and unrebutted by the defense.  The trial

court not surprisingly noted that Rodessa's narration in detail of her father's monstrous

acts had made her cry.[11] Once again, we rule that:

"x x x The testimony of the victim who was only 12 years old at the time of the rape as

to the circumstances of the rape must be given weight for testimony of young and

immature rape victims are credible (People v. Guibao, 217 SCRA 64 [1993]).  No

woman especially one of tender age, practically only a girl, would concoct a story of

defloration, allow an examination of her private parts and thereafter expose herself to a

public trial, if she were not motivated solely by the desire to have the culprit

apprehended and punished (People v. Guibao, supra)."[12]

The accused-appellant points out certain inconsistencies in the testimonies of the

prosecution witnesses in his attempt to bolster his claim that the rape accusation

against him is malicious and baseless.  Firstly, Rodessa's testimony that the accused-

appellant was already naked when he dragged her inside the room is inconsistent with

her subsequent testimony that the said accused-appellant was still wearing short pants

when she was dragged inside the room.  Secondly, Rodessa's sworn statement before

the police investigator which indicated that, while the accused was executing pumping

acts, he uttered the words "Masarap ba?", differ from her testimony in court wherein

she related that when the accused took out his penis from her vagina, the accused said
"Masarap, tapos na." Thirdly, the victim's grandmother, Asuncion Rivera, recounted in

her sworn statement that it was the accused who went to see her to apprise her of the

rape committed on her granddaughter.  However, in her testimony in court, Asuncion

Rivera claimed that she was the one who invited the accused-appellant to see her in

her house so as to tell her a secret. [13] These alleged discrepancies merely pertain to

minor details which in no way pose serious doubt as to the credibility of the prosecution

witnesses.  Whether or not the accused was naked when he dragged Rodessa inside

the room where he sexually assaulted her bears no significant effect on Rodessa's

testimony that she was actually raped by the accused-appellant.  Moreover, a

conflicting account of whatever words were uttered by the accused-appellant after he

forcefully inserted his penis into Rodessa's private organ against her will cannot impair

the prosecution's evidence as a whole.  A determination of which version earmarks the

truth as to how the victim's grandmother learned about the rape is inconsequential to

the judgment of conviction.

As we have pronounced in the case of People v. Jaymalin:[14]

"This Court has stated time and again that minor inconsistencies in the narration of a

witness do not detract from its essential credibility as long as it is on the whole

coherent and intrinsically believable.   Inaccuracies may in fact suggest that the witness

is telling the truth and has not been rehearsed as it is not to be expected that he will be

able to remember every single detail of an incident with perfect or total recall."
After due deliberation, this Court finds that the trial judge's assessment of the credibility

of the prosecution witnesses deserves our utmost respect in the absence of

arbitrariness.

With respect to the second assigned error, the records of the instant case are bereft of

clear and concrete proof of the accused-appellant's claim as to the size of his penis and

that if that be the fact, it could not have merely caused shallow healed lacerations at

3:00 and 7:00 o'clock.[15] In his testimony, the accused- appellant stated that he could

not have raped Rodessa because of the size of his penis which could have ruptured her

vagina had he actually done so.[16] This Court gives no probative value on the accused-

appellant's self-serving statement in the light of our ruling in the case of People v.

Melivo, supra,[17] that:

"The vaginal wall and the hymenal membrane are elastic organs capable of varying

degrees of distensibility.  The degree of distensibility of the female reproductive organ

is normally limited only by the character and size of the pelvic inlet, other factors being

minor.  The female reproductive canal being capable of allowing passage of a regular

fetus, there ought to be no difficulty allowing the entry of objects of much lesser size,

including the male reproductive organ, which even in its largest dimensions, would still

be considerably smaller than the full-term fetus.

xxx                                                 xxx                                        xxx

In the case at bench, the presence of healed lacerations in various parts of the vaginal

wall, though not as extensive as appellant might have expected them to be, indicate
traumatic injury to the area within the period when the incidents were supposed to

have occurred." (At pp. 13-14, Italics supplied)

In rape cases, a broken hymen is not an essential element thereof. [18] A mere knocking

at the doors of the pudenda, so to speak, by the accused's penis suffices to constitute

the crime of rape as full entry into the victim's vagina is not required to sustain a

conviction.[19] In the case, Dr. Freyra, the medico-legal examiner, categorically testified

that the healed lacerations of Rodessa on her vagina were consistent with the date of

the commission of the rape as narrated by the victim to have taken place in April, 1994.

[20]

Lastly, the third assigned error deserves scant consideration.  The accused-appellant

erroneously argues that the Contract of Services (Exhibit 4) offered as evidence in

support of the accused-appellant's defense of alibi need not be corroborated because

there is no law expressly requiring so.[21] In view of our finding that the prosecution

witnesses have no motive to falsely testify against the accused-appellant, the defense

of alibi, in this case, uncorroborated by other witnesses, should be completely

disregarded.[22] More importantly, the defense of alibi which is inherently weak becomes

even weaker in the face of positive identification of the accused-appellant as

perpetrator of the crime of rape by his victim, Rodessa.[23]

The Contract of Services whereby the accused-appellant obligated himself to do some

painting Job at the house of one Divina Ang in Paranaque, Metro Manila, within 25 days

from April 4, 1994, is not proof of the whereabouts of the accused-appellant at the time

of the commission of the offense.

complaint, dated July 14, 1994.  The gravamen of the said offense, as stated in

paragraph 3, Article 335 of the Revised Penal Code, is the carnal knowledge of a

woman below twelve years old.[24] Rodessa positively identified his father accused-

appellant, succeeded in consummating his grievous and odious sexual assault on her is

free from any substantial self-contradiction.  It is highly inconceivable that it is

rehearsed and fabricated upon instructions from Rodessa's maternal grandmother

Asuncion Rivera as asserted by the accused-appellant.  The words of Chief Justice

Enrique M. Fernando, speaking for the Court, more than two decades ago, are relevant

and worth reiterating, thus:

"x x x it is manifest in the decisions of this Court that where the offended parties are

young and immature girls like the victim in this case, (Cited cases omitted) there is

marked receptivity on its part to lend credence to their version of what transpired.  It is

not to be wondered at.  The state, as parens patria, is under the obligation to minimize

the risk of harm to those, who, because of their minority, are as yet unable to take care

of themselves fully.  Those of tender years deserve its utmost protection.  Moreover,

the injury in cases of rape is not inflicted on the unfortunate victim alone.  The

consternation it causes her family must also be taken into account.  It may reflect a

failure to abide by the announced concern in the fundamental law for such

institution.  There is all the more reason then for the rigorous application of the penal

law with its severe penalty for this offense, whenever warranted.  It has been aptly

remarked that with the advance in civilization, the disruption in public peace and order
it represents defies explanation, much more so in view of what currently appears to be

a tendency for sexual permissiveness.  Where the prospects of relationship based on

consent are hardly minimal, self-restraint should even be more marked." [25]

Under Section 11 of Republic Act No. 7659 often referred to as the Death Penalty Law,

Art. 335 of the Revised Penal Code was amended, to wit:

"The death penalty shall also be imposed if the crime of rape is committed with any of

the following attendant circumstances:

1.  When the victim is under eighteen (18) years of age and the offender is a parent,

ascendant, step-parent, guardian, relative by consanguinity or affinity within the third

civil degree, or the common-law spouse of the parent of the victim.

xxx                                                 xxx                                        xxx

(Italics supplied)

Apparently, as a last glimpse of hope, the accused-appellant questions the penalty

imposed by the trial court by declaring that he is neither a father, stepfather or

grandfather of Rodessa although he was a confirmed lover of Rodessa's mother. [26] On

direct examination, he admitted that before the charge of rape was filed against him,

he had treated Rodessa as his real daughter and had provided for her food, clothing,

shelter and education.[27] The Court notes that Rodessa uses the surname of the

accused-appellant, not Rivera (her mother's maiden name) nor Alfonso (her

grandmother's live-in partner).  Moreover, Rodessa's mother stated during the cross-

examination that she, the accused-appellant and her five children, including Rodessa,
had been residing in one house only.[28] At any rate, even if he were not the father,

stepfather or grandfather of Rodessa, this disclaimer cannot save him from the abyss

where perpetrators of heinous crimes ought to be, as mandated by law.  Considering

that the accused-appellant is a confirmed lover of Rodessa's mother, [29] he falls squarely

within the aforequoted portion of the Death Penalty Law under the term "common-law

spouse of the parent of the victim."

The fact that the ten-year old Rodessa referred to the accused-appellant as "Papa" is

reason enough to conclude that accused-appellant is either the father or stepfather of

Rodessa.  Thus, the act of sexual assault perpetrated by the accused on his young

victim has become all the more repulsive and perverse.  The victim's tender age and

the accused-appellant's moral ascendancy and influence over her are factors which

forced Rodessa to succumb to the accused's selfish and bestial craving.  The law has

made it inevitable under the circumstances of this case that the accused-appellant face

the supreme penalty of death.

WHEREFORE, we AFFIRM the decision of the Regional Trial Court of Quezon City,

Branch 104.

, judgment is hereby rendered finding accused LEO ECHEGARAY Y PILO guilty beyond

reasonable doubt of the crime of RAPE as charged in the complaint, aggravated by the

fact that the same was committed by the accused who is the father/stepfather of the

complainant, he is hereby sentenced to suffer the penalty of DEATH, as provided for

under RA. No. 7659; to pay the complainant Rodessa Echegaray the sum of P50,000.00
as damages, plus all the accessory penalties provided by law, without subsidiary

imprisonment in case of insolvency, and to pay the costs."[1]

We note, however, that the charge had been formulated in this manner:

"C O M P L A I N T

The undersigned accuses LEO ECHEGARAY Y PILO of the crime of RAPE, committed as

follows:

That on or about the month of April 1994, in Quezon City, Philippines, the above-named

accused, by means of force and intimidation, did then and there, wilfully, unlawfully and

feloniously have carnal knowledge of the undersigned complainant his daughter, a

minor, 10 years of age, all against her will and without her consent, to her damage and

prejudice.

CONTRARY TO LAW."[2]

Upon being arraigned on August 1, 1994, the accused-appellant, assisted by his

counsel de oficio, entered the plea of "not guilty."

President Rodrigo Duterte once more pushed for the reimposition of capital

punishment, specifying the method of lethal injection, for heinous crimes related to

illegal drugs in his fifth State of the Nation Address.

vowed to fight criminality, said executions will help lower crime rates in the country.

“I reiterate the swift passage of a law reviving the death penalty by lethal injection for

crimes specified under the Comprehensive Dangerous Drugs Act of 2002,” he said in his

speech on Monday.

“This law will not only help us deter criminality, but also save our children from the

dangers posed by the illegal and dangerous drugs,” he stressed.

This statement came after Duterte said his administration believes that freedom from

illegal drugs, among other illicit acts, is a human right. He warned that those who

commit drug crimes in the country will be met with execution, saying, "I will really kill

you. That is a commitment.”

READ: SONA 2020: Duterte says gov't will 'not dodge' obligation to fight for human

rights
In an interview with CNN Philippines, Senator Ronald “Bato” Dela Rosa said Duterte’s

call is “a big boost” to the corresponding measure he filed in June 2019, which seeks to

reinstate the penalty for drug traffickers.

“Matagal ko na kasing na-file ‘yung death penalty against drug trafficking, but until now

it's languishing at the referred committee kaya malaking boost 'yung pakikiusap ni

Pangulo sa ating Kongreso,” he said.

[Translation: I have long filed a bill seeking to revive the death penalty for drug

trafficking, but until now it’s languishing at the referred committee, so the President’s

appeal to Congress is a big boost.]

Dela Rosa said imposing a death sentence is necessary to effectively fight the illegal

drug trade.

“Dapat talagang bitayin 'yang mga drug lord na 'yan,” he said. “Sabi sa'kin ng mga drug

lord sa Bilibid, kung gusto raw talaga ng gobyerno mahinto o mabawasan man lang

'yung drug trafficking, kailangan ibalik daw talaga ‘yung death penalty.”
[Translation: Drug lords should really be hanged. The drug lords in Bilibid told me that

if the government really wants to stop or at least lessen drug trafficking, the death

penalty should be reinstated.]

The senator refuted concerns that the death penalty is anti-poor, saying there is no

“small-time” drug trafficker, and that all drug lords “can hire the best lawyer.”

Critics have argued against the measure, saying the poor are more likely to be executed

than wealthy inmates. Those against the measure also cite the high rate of judicial

errors, which may result in the death of innocent people.

In June, the United Nations’ human rights chief Michelle Bachelet said that the

extrajudicial killings and other abuses in the country were a result of the Duterte

administration's anti-drug policies.

READ: UN rights chief says Duterte drug war without regard for due process, human

rights

Duterte said last year that to lessen expenses, his preferred method of killing criminals

— should Congress heed his plea — is hanging by rope.

was passed by the House of Representatives, but was stalled in the Senate.

The 1987 Constitution abolished the death penalty but allowed Congress to bring it

back for heinous crimes. It was revived under the administration of President Fidel

Ramos, but was scrapped again under President Gloria Macapagal-Arroyo.

NOTES FOR CORRECTION:

1. Kindly paraphrase your Background of the Study. Most of the content

here were found on the internet and were not given revisions. Original

Text from the Internet is just the same as the text on the research

paper. Make sure that after paraphrasing this long background of the

study, you will only create a content/background filling out at least 1-2

pages.