G.R. No. 172607 - People vs. Umanito

On January 9, 1990, Rufino Umanito (appellant) was charged with rape allegedly committed on July 15, 1989 at around 9:00 PM in Brgy. Daramuangan, Naguilian, La Union.
The complaint alleged that appellant, armed with a fan knife, by force and threats, had sexual intercourse with AAA, an unmarried girl over 12 but under 18 years of age, to her damage and prejudice.

Appellant was arrested in 1995 when he sought a police clearance, pleaded not guilty at arraignment, and went to trial before RTC Branch 67, Bauang.
Victim AAA testified she was waylaid by appellant at a creek, threatened with a knife, dragged into a school building, raped on a bench, and later threatened not to report him. She only disclosed the incident to her mother six months later upon noticing her stomach’s prominence.
Appellant’s defense was alibi—he claimed he was at home working on picture frames the entire day—and asserted a non-sexual acquaintance with AAA.
The RTC, finding AAA credible despite minor inconsistencies and rejecting the alibi, convicted appellant of rape, imposed reclusion perpetua, and ordered P50,000 indemnity.
On February 15, 2006, the Court of Appeals affirmed, holding that trivial inconsistencies did not impair AAA’s credibility.

AAA bore a child alleged to have been conceived from the rape.
The Supreme Court observed that DNA testing could conclusively establish whether appellant was the father, potentially raising reasonable doubt.

Whether the prosecution proved appellant’s guilt beyond reasonable doubt considering the delay in filing the complaint and inconsistencies in AAA’s testimony.

Whether DNA testing should be ordered to determine appellant’s paternity of AAA’s child and, if negative, justify his acquittal or cast reasonable doubt on the rape conviction.