Ong Ting Ting v PP: Maid Abuse Appeal - Voluntarily Causing Hurt & Criminal Intimidation Sentencing
Ong Ting Ting appealed to the High Court of Singapore against her conviction and sentence for maid abuse. She was convicted on four charges of voluntarily causing hurt, two charges of using criminal force, and one charge of criminal intimidation against her maid, Jean Ganzon. Yong Pung How CJ dismissed both appeals, finding the district judge's assessment of the evidence to be sound and the sentence appropriate, considering the aggravating factors of the abuse.
1. Case Overview
1.1 Court
High Court1.2 Outcome
Appeals against conviction and sentence dismissed.
1.3 Case Type
Criminal
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Ong Ting Ting appeals conviction and sentence for maid abuse involving voluntarily causing hurt and criminal intimidation. Appeal dismissed.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Public Prosecutor | Respondent | Government Agency | Judgment Upheld | Won | Christopher Ong Siu Jin of Deputy Public Prosecutor |
| Ong Ting Ting | Appellant | Individual | Appeal Dismissed | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Yong Pung How | Chief Justice | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Christopher Ong Siu Jin | Deputy Public Prosecutor |
| Wee Pan Lee | Wee Tay and Lim |
4. Facts
- The appellant was convicted of maid abuse against Jean Ganzon.
- The abuse occurred on 13 July 2002 at the appellant's residence.
- The appellant pushed, poured water on, and placed ice cubes on Jean.
- The appellant threatened to kill Jean.
- Jean ran away to the Embassy of the Philippines and made a police report.
- Dr. Tan found injuries on Jean consistent with the abuse.
5. Formal Citations
- Ong Ting Ting v Public Prosecutor, MA 241/2003, [2004] SGHC 156
6. Timeline
| Date | Event |
|---|---|
| Ong Ting Ting approached Arrow Employment Agency for a Filipino maid. | |
| Jean Ganzon claimed Ong Ting Ting hit her arm and pushed her. | |
| Incident of maid abuse occurred. | |
| Jean Ganzon ran away to the Embassy of the Philippines and made a police report. | |
| Appellant was charged with four counts of voluntarily causing hurt, two counts of using criminal force and one count of criminal intimidation. | |
| Appeals against conviction and sentence dismissed. |
7. Legal Issues
- Appeal Against Findings of Fact
- Outcome: The court upheld the trial judge's findings of fact, finding no error in the assessment of evidence.
- Category: Procedural
- Sub-Issues:
- Weight of evidence
- Credibility of witnesses
- Related Cases:
- [2000] 4 SLR 96
- [1992] 1 SLR 713
- [1997] 3 SLR 464
- Mitigation in Sentencing
- Outcome: The court found that the lack of antecedents should have been considered as an additional mitigating factor, but ultimately did not disturb the sentence.
- Category: Substantive
- Sub-Issues:
- Lack of antecedents
- Multiple offences relating to a single incident
- Related Cases:
- [2003] 2 SLR 334
- Manifestly Excessive Sentence
- Outcome: The court found that the sentence was not manifestly excessive, considering the aggravating factors of the abuse.
- Category: Substantive
- Sub-Issues:
- Maid abuse
- Voluntarily causing hurt
- Criminal use of force
- Criminal intimidation
- Related Cases:
- [2002] 1 SLR 117
- [2003] 1 SLR 129
8. Remedies Sought
- Appeal against Conviction
- Appeal against Sentence
9. Cause of Actions
- Voluntarily Causing Hurt
- Using Criminal Force
- Criminal Intimidation
10. Practice Areas
- Criminal Appeals
- Sentencing
- Maid Abuse
11. Industries
- Employment Agency
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Kwan Peng Hong v PP | High Court | Yes | [2000] 4 SLR 96 | Singapore | Cited for the principle that the court must be extremely cautious in convicting the appellant based solely on the maid's allegations. |
| PP v Gan Lim Soon | High Court | Yes | [1993] 3 SLR 261 | Singapore | Cited for the principle that it is the broad facts, and not the little details, that mattered. |
| Lim Ah Poh v PP | High Court | Yes | [1992] 1 SLR 713 | Singapore | Cited for the principle that an appellate court would be slow to overturn a trial judge’s findings of fact, having not had the opportunity to see and hear the witnesses. |
| Sundara Moorthy Lankatharan v PP | High Court | Yes | [1997] 3 SLR 464 | Singapore | Cited for the principle that an appellate court would be slow to overturn a trial judge’s findings of fact, having not had the opportunity to see and hear the witnesses. |
| Chean Siong Guat v PP | High Court | Yes | [1969] 2 MLJ 63 | Malaysia | Cited for the principle that minor inconsistencies should be disregarded. |
| PP v Kalpanath Singh | High Court | Yes | [1995] 3 SLR 564 | Singapore | Cited for the principle that minor inconsistencies should be disregarded. |
| PP v Datuk Haji Harun bin Haji Idris (No 2) | Federal Court | Yes | [1977] 1 MLJ 15 | Malaysia | Cited for the principle that the court is entitled, for good and cogent reasons, to accept one part of the testimony of a witness and to reject the other. |
| Ng Kwee Leong v PP | High Court | Yes | [1998] 3 SLR 942 | Singapore | Cited for the principle that the court is entitled, for good and cogent reasons, to accept one part of the testimony of a witness and to reject the other. |
| Tan Pin Seng v PP | High Court | Yes | [1998] 1 SLR 418 | Singapore | Cited for the principle that a police report is simply meant to provide information of a cognisable offence to the police, so as to set the investigation in motion. |
| Chen Weixiong Jerriek v PP | High Court | No | [2003] 2 SLR 334 | Singapore | Cited regarding the consideration of lack of prior convictions as a mitigating factor. |
| PP v Chong Siew Chin | High Court | Yes | [2002] 1 SLR 117 | Singapore | Cited regarding the harsh stance on cases of maid abuse and the need for deterrent sentences. |
| Farida Begam d/o Mohd Artham v PP | High Court | Yes | [2001] 4 SLR 610 | Singapore | Cited regarding the protection of maids under the law. |
| Ho Yean Theng Jill v PP | High Court | Yes | [2004] 1 SLR 254 | Singapore | Cited regarding the impermissibility of employers venting frustration on maids. |
| Woon Salvacion Dalayon v PP | High Court | Yes | [2003] 1 SLR 129 | Singapore | Cited regarding the sentencing for criminal intimidation. |
| Lee Yoke Choong v PP | High Court | Yes | [1964] 1 MLJ 138 | Malaysia | Cited regarding the relevance of intention and fear in determining the extent of a serious threat. |
| PP v Luan Yuanxin | High Court | Yes | [2002] 2 SLR 98 | Singapore | Cited regarding the relevance of intention and fear in determining the extent of a serious threat. |
13. Applicable Rules
| Rule Name |
|---|
| Rules of Court (Cap 322, R 5, 1997 Rev Ed) |
| O 18 r 7(1) |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Penal Code (Cap 224, 1985 Rev Ed) | Singapore |
| s 323 | Singapore |
| s 73(2) | Singapore |
| s 352 | Singapore |
| s 506 | Singapore |
| Criminal Procedure Code (Cap 68, 1985 Rev Ed) | Singapore |
| s 18 | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Maid abuse
- Voluntarily causing hurt
- Criminal force
- Criminal intimidation
- Mitigation
- Manifestly excessive
- Findings of fact
15.2 Keywords
- Maid abuse
- Voluntarily causing hurt
- Criminal intimidation
- Singapore
- Appeal
- Sentencing
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Maid Abuse | 95 |
| Criminal Law | 90 |
| Sentencing | 90 |
| Criminal Procedure | 90 |
| Offences | 70 |
| Personal Injury | 60 |
| Torts | 30 |
16. Subjects
- Criminal Law
- Sentencing
- Maid Abuse
- Criminal Procedure