Case Summary (G.R. No. 175124)
Supreme Court Remand for DNA Testing
Recognizing inconsistent assertions by prosecution and defense—especially Umanito’s alibi and AAA’s evolving testimony—the Supreme Court, for the first time applying the New Rules on DNA Evidence, remanded the case on October 26, 2007. It directed the RTC to receive DNA evidence under Sections 4(a), (b), (c), and (e) of A.M. No. 06-11-5-SC and appointed DCA Reuben De la Cruz to monitor compliance.
DNA Testing Proceedings and Chain of Custody
At the November 27, 2007 hearing, AAA and BBB expressed willingness to undergo DNA testing; on December 5, 2007, parties agreed to designate the NBI as testing institution. The RTC ordered sample collection under strict chain-of-custody measures: neutral collection, tamper-evident sealing, identity verification, and confidentiality safeguards. On January 9, 2008, samples from AAA and BBB were taken before Judge Fe, prosecutor, defense counsel, and DCA De la Cruz. Umanito’s sample was collected February 8, 2008 at New Bilibid Prisons under identical protocols.
DNA Results and Paternity Presumption
At the March 28, 2008 admissibility hearing, NBI chemist Mary Ann Aranas testified on using the PowerPlex 16 System for 15 polymorphic loci. She reported a complete 15-loci match between Umanito and BBB, yielding a 99.9999% probability of paternity. Exhibits “A” (lab report) and “B” (enlarged profile table) were admitted without objection. Under Section 6 of A.M. 06-11-5-SC, this result gave rise to a disputable presumption that Umanito is BBB’s biological father.
Defense’s Failure to Contest and Alibi Rebuttal
Umanito’s counsel declined to present evidence to rebut the paternity presumption at the April 29, 2008 hearing. The DNA findings directly contradicted his alibi a
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Facts of the Case
- In 1989, AAA alleged she was raped by Rufino Umanito, resulting in her pregnancy and the birth of a daughter, BBB, on 5 April 1990
- The Regional Trial Court (RTC) of Bauang, La Union, Branch 67 found Umanito guilty beyond reasonable doubt of rape
- Umanito was sentenced to reclusion perpetua and ordered to pay AAA ₱50,000.00 in civil indemnity
Procedural History
- The Court of Appeals affirmed the RTC’s judgment on appeal
- Umanito elevated his appeal to the Supreme Court (SC)
- On 26 October 2007, the SC resolved to apply the newly promulgated New Rules on DNA Evidence (A.M. No. 06-11-5-SC, effective 15 October 2007) for the first time in this pending case
- The SC remanded the matter to the RTC for reception of DNA evidence and directed Deputy Court Administrator (DCA) Reuben Dela Cruz to monitor implementation and report periodically
Issues Presented
- Whether Umanito is the biological father of BBB, whose maternity is undisputed
- Whether conclusive DNA results could cast reasonable doubt on or reinforce the rape conviction
Application of the New DNA Rules
- The SC recognized “incongruent assertions” by prosecution and defense regarding Umanito’s relationship with AAA and his alibi defense
- SC Observation: Conclusive DNA testing could determine paternity with reasonable certainty and potentially yield acquittal if Umanito were excluded as father
- SC Directive: AAA, BBB and Umanito were ordered to submit to DNA testing under the New Rules on DNA Evidence
Remand Proceedings in the RTC
- RTC scheduled a feasibility hearing on 27 November 2007 under Sections 4(a), (b), (c) and (e) of the DNA Rules
- AAA and BBB testified and manifested willingness to undergo testing
- On 5 December 2007, prosecution and defense agreed to designate the National Bureau of Investigation (NBI) as the testing laboratory
- RTC issued a detailed order for chain-of-cu