The Revised Penal Code was enacted in f 1930. It is a reflection of what society perceived women to be. Premium was given to virginity and good reputation of a Filipina. Even the decisions of the Supreme Court depict Filipino women as shy, meek, virginal. There were also provisions of this Code that discriminated against women that had to be amended to apply to both men and women such as Art. 247 (Death Under Exceptional Circumstances).

Through the years and through the advocacy of women's groups there had been many changes. The Anti- Rape Law and the Sexual Harassment Law -were enacted. But there is still a need for the enactment of laws such as the Domestic Violence Act to address violence in the family. It is the hope that in due time our penal laws will be more responsive to the needs of women.