Clara is characterized as reserved and shy and was later considered an "ideal" role model for women in Filipino culture,[2] although such notion was imposed by Spanish colonizers.
[3] The doctrine became a part of the Supreme Court of the Philippines' jurisprudence some time in 1960 following the People v. Taño case.
[4] The case involved three armed robbers who the court found liable for taking turns in raping a woman.
[6] The case involved an alleged rape that happened in 2009 and the two accused were sentenced of reclusión perpetua, or forty years of imprisonment, in 2012.
It urged for the acceptance of the "realities of a woman’s dynamic role" in Philippine society today so one can "evaluate the testimony of a private complainant of rape without gender bias or cultural misconception".