Case Digest (G.R. No. 16444) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Emeteria Villaflor v. Ricardo Summers, decided on September 8, 1920, the petitioner, Emeteria Villaflor, was charged with adultery alongside Florentino Souingco before the Court of First Instance of Manila. During her trial presided over by Judge Pedro Concepcion, the assistant fiscal petitioned the court to have one or two competent physicians examine Villaflor to determine if she was pregnant. Villaflor objected, asserting that such an examination violated her constitutional right against self-incrimination under the Philippine Bill of Rights and the Fifth Amendment of the U.S. Constitution as incorporated by the President’s Instructions to the Philippine Commission (Act of July 1, 1902, §5(3); Act of August 29, 1916, §3(3); Code of Criminal Procedure, §15[4]). The trial court found her in contempt for refusing the order and committed her to Bilibid Prison until she submitted to the examination Case Digest (G.R. No. 16444) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Criminal proceedings
- Emeteria Villaflor and Florentino Souingco were jointly charged with adultery before the Court of First Instance of the City of Manila.
- The assistant fiscal petitioned the court to order a medical examination of Villaflor to determine if she was pregnant.
- Contempt order and custody
- Villaflor refused the court’s order, invoking the constitutional protection against self-incrimination.
- Judge Pedro Concepcion held her in contempt and committed her to Bilibid Prison until she submitted to the examination.
Issues:
- Constitutional question
- Does compelling a defendant to undergo a medical examination of her person to ascertain pregnancy violate the privilege against self-incrimination as guaranteed by the Philippine Bill of Rights and the Code of Criminal Procedure?
- Should bodily exhibition for physical evidence be treated as testimonial compulsion prohibited by the Fifth Amendment of the U.S. Constitution and its Philippine counterparts?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)