"A person who penetrates an act of sexual intercourse with a female not his wife, against her will or without her consent. .. [i]s guilty of rape in the first degree and punishable by imprisonment for not more than twenty years. A person who penetrates an act of sexual intercourse with a female, not his wife, under the age of eighteen years, under circumstances not amounting to rape in the first degree, is guilty of rape in the second degree, and punishable with imprisonment for not more than ten years." Id., citing the 1922 case of People v. Meli (193 N .Y.S. 365 [Sup. Ct. 1922]). John Meli was convicted of rape for aiding and abetting another man in raping his wife. Meli did not commit the rape himself but he was present while the rape was being committed and he actually helped to overcome his wife. 98 Racquel Kennedy Bergen, Ph.D., Marital Rape, Applied Research Forum, National Electronic Network on Violence Against Women, p. 2 (1999). www.hawaii.edu/hivandaids/Marital Rape.pdf, last accessed on April 1, 2014, citing Bidwell, L., & White, P., The family context of marital rape. The Journal of Family Violence, I, pp. 277287 (1986) and Finkelhor, D., & Yllo, K., License to Rape: Sexual Abuse of Wives, New York: Holt, Rinehart & Winston (1985). 99 100 People v. Liberta, supra note 92. 101 Id. 102 Id. Bergen, supra note 99, citing Bergen, R.K., Wife Rape: Understanding the Response of Survivors and Service Providers. Thousand Oaks, CA: Sage (1996) and Russell, D.E.H., Rape in Marriage, New York, Macmillan Press (1990). 103 104 Tenure: November 20, 1985 to March 6, 1986. Ramon C. Aquino, The Revised Penal Code, Volume Ill, Central Lawbook Supply, Inc. (1988 Ed.), pp. 382-383. 105 http://pcw.gov.ph/intemational-commitments/cedaw/state-obligations, last visited on March 20, 2014; CEDAW came into effect on September 4, 1981, the Philippines has signed it on July 17, 1980 and ratified it on July 19, 1981, the first Association of South East Asian Nation country to do so. 106 CA Associate Justice Myrna Dimaranan-Vidal, Women Empowerment, http://ca.judiciary.gov.ph/index.php?action=mnuactual_contents&ap=j8040&p=y, last accessed on April 1, 2014. 107 108 CEDA W, Article 2, Part I. Also known as The Anti-Rape Law of 1997, the law took effect on October 22, 1997; See People v. Maceda, 405 Phil. 698, 721 (2001). 109 110 Consideration of the Conference Committee Reports, September 3, 1997.