Case Digest (G.R. No. 148220) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On May 14, 1998, Rosendo Alba, then a thirteen-year-old minor represented by his mother Armi A. Alba, filed before Branch 48 of the Regional Trial Court of Manila (Civil Case No. SP 98-88759) a petition for compulsory recognition, support and damages against Rosendo Herrera, claiming Herrera as his biological father. On August 7, 1998, Herrera filed his Answer with Counterclaim, categorically denying paternity and any intimate relations with Alba’s mother. To expedite the proceedings, Alba moved the trial court to direct all parties to submit to DNA paternity testing, supporting the motion with the testimony of Dr. Saturnina C. Halos, Ph.D., an expert in molecular biology and head of the UP-NSRI DNA Analysis Laboratory, who explained the methodology and 99.9999% accuracy rate of DNA profiling. Herrera opposed the test, arguing its scientific reliability was not yet established in Philippine jurisprudence and that compulsory sampling would violate his right against self-incrimina Case Digest (G.R. No. 148220) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Case
- Petitioner: Rosendo Herrera, alleged putative father.
- Respondent: Rosendo Alba (minor), by his mother Armi A. Alba; Hon. Nimfa Cuesta-Vilches, RTC-Manila Branch 48.
- Nature of action: Petition for review of CA decision affirming trial court orders compelling petitioner to submit to DNA paternity testing.
- Trial Court Proceedings
- May 14, 1998 – Armi Alba filed SP No. 98-88759 for compulsory recognition, support and damages.
- August 7, 1998 – Herrera answered with counterclaim denying paternity and sexual contact.
- Respondent moved for DNA paternity testing; presented Dr. Saturnina C. Halos as expert, who testified on DNA testing accuracy (99.9999%).
- Herrera opposed on grounds of scientific acceptability and violation of right against self-incrimination.
- Orders and Appeal
- February 3, 2000 – RTC ordered Herrera, the child and mother to submit DNA specimens and report results.
- June 8, 2000 – RTC denied Herrera’s motion for reconsideration.
- July 18, 2000 – Herrera filed CA certiorari petition under Rule 65, alleging grave abuse of discretion and lack of jurisdiction; reiterated objections to DNA testing.
- November 29, 2000 – CA denied petition, affirmed RTC orders; ruled DNA testing does not violate self-incrimination and is subject to later rebuttal.
- May 23, 2001 – CA denied reconsideration.
Issues:
- Admissibility and Legal Validity of DNA Testing
- Whether DNA analysis is a recognized, reliable probative tool in paternity/filiation suits in the Philippines.
- Conditions and prerequisites for its admissibility under Philippine law and evidentiary rules.
- Constitutional Objection
- Whether compelling the petitioner to provide DNA samples violates his right against self-incrimination (Art. III, Sec. 17, 1987 Constitution).
- Jurisdictional and Procedural Claims
- Whether the RTC orders were rendered in excess or without jurisdiction and with grave abuse of discretion.
- Whether an adequate remedy by appeal exists.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)