Case Digest (G.R. No. 108921) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Rufino Umanito, the respondent Rufino Umanito was charged with the 1989 rape of AAA, which allegedly resulted in her pregnancy and the birth of a child (BBB) on April 5, 1990. The Regional Trial Court (RTC) of Bauang, La Union, Branch 67, presided by Judge Ferdinand A. Fe, found Umanito guilty beyond reasonable doubt, sentenced him to reclusion perpetua, and ordered him to indemnify the private complainant in the amount of ₱50,000.00. The Court of Appeals affirmed the RTC decision on February 15, 2006, and Umanito appealed to the Supreme Court. In its October 26, 2007 Resolution, the Supreme Court, invoking the newly promulgated New Rules on DNA Evidence (A.M. No. 06-11-5-SC, effective October 15, 2007), remanded the case to the RTC for DNA testing of Umanito, AAA, and BBB to determine paternity. The remand order directed strict compliance with chain of custody procedures and confidentiality measures overseen by Deputy Court Administrator Reuben D Case Digest (G.R. No. 108921) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- In 1989, AAA alleged she was raped by Rufino Umanito, resulting in pregnancy and birth of a daughter, BBB, in April 1990.
- The RTC of Bauang, La Union, Branch 67 found Umanito guilty of rape, sentenced him to reclusion perpetua, and ordered indemnity of ₱50,000.00; the Court of Appeals affirmed.
- Remand for DNA Testing
- On 26 October 2007, the Supreme Court issued A.M. No. 06-11-5-SC (DNA Rules) and remanded the case to the RTC to apply these rules, directing monitoring by the Deputy Court Administrator.
- The RTC set hearings (27 Nov. 2007; 5 Dec. 2007) to determine feasibility and procedures under Sections 4(a), (b), (c), (e) of the DNA Rules. Parties agreed to engage the NBI for testing.
- Collection and Analysis of Samples
- On 9 Jan. 2008 (AAA and BBB) and 8 Feb. 2008 (Umanito at New Bilibid Prisons), NBI chemists, in presence of the court, prosecution, defense counsel, and DCA De la Cruz, collected buccal swabs and blood on FTA cards following strict chain-of-custody protocols (identification, tamper-tape sealing, witness signatures).
- The RTC ordered submission of results within 30 days and set hearings on 10 Mar., 28 Mar., and 29 Apr. 2008 to admit and allow parties to challenge DNA evidence. Umanito presented no contrary evidence or objection.
- DNA Test Results and Lower Court Findings
- NBI used the PowerPlex 16 System to examine 15 loci, finding a complete match between Umanito and BBB; probability of paternity was 99.9999%.
- Pursuant to Section 6 of the DNA Rules, a ≥ 99.9% probability gives rise to a disputable presumption of paternity. Umanito did not contest, thus RTC ruled he is the biological father.
- Motion to Withdraw Appeal
- On 16 Feb. 2009, Umanito moved to withdraw his appeal, deemed an acceptance of lower courts’ rulings and penalties.
Issues:
- Whether the Supreme Court correctly applied the New Rules on DNA Evidence to a pending case.
- Whether the DNA evidence collected and processed by the NBI met admissibility standards (chain of custody, expert qualifications, testing procedures).
- Whether a 99.9999% probability of paternity under the DNA Rules gives rise to a disputable presumption sufficient to establish filiation.
- Whether the motion to withdraw appeal effectively renders the decision of the RTC and the Court of Appeals final.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)