PP v. Umanito

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PP v Umanito

Doctrine: Deoxyribonucleic Acid (DNA) print or identification technology is now recognized as a uniquely
effective means to link a suspect to a crime, or to absolve one erroneously accused, where biological
evidence is available—for purposes of criminal investigation, Deoxyribonucleic Acid (DNA) identification
is a fertile source of both inculpatory and exculpatory evidence.

Facts: The appellee (victim) alleged in the original complaint that the appellant (accused) raped her. The
latter’s defense is that he was home the whole day, helping his family complete rush work.

During trial there are some inconsistencies in the victim’s testimony.

The RTC rendered its decision against the accused.

In so doing, the court a quo held that the discrepancies in AAA’s testimony did not impair her credibility.
Despite some inconsistencies in her statement, the RTC observed that AAA’s demeanor on the witness
stand did not indicate any falsehood in her narration.

The trial court likewise rejected appellant’s defense of alibi, ruling that he did not prove that it was
physically impossible for him to be at the scene of the crime given the testimonies that he and
complainant were residing in the same barrio.

It was elevated to the court of appeals but it just affirmed the decision of the RTC.

Finding AAA to be a credible witness, the Court of Appeals agreed with the trial court that the
inconsistencies in her statements were too trivial and inconsequential to impair the credibility of her
testimony.

Issue: Whether or not the New Rule on DNA Evidence is applicable in this case.

Guys, di ko magets yung decision ng SC bakit nagsuggest ng additional evidence na DNA Test Result.

Bale hindi sya contention ng both parties, pinagawa lang tlga sya ni SC.

Ruling: Amidst the slew of assertions and counter-assertions, a happenstance may provide the definitive
key to the absolution of the appellant. This is the fact that AAA bore a child as a result of the purported
rape. With the advance in genetics and the availability of new technology, it can now be determined
with reasonable certainty whether appellant is the father of AAA’s child. If he is not, his acquittal may be
ordained. We have pronounced that if it can be conclusively determined that the accused did not sire
the alleged victim’s child, this may cast the shadow of reasonable doubt and allow his acquittal on this
basis. If he is found not to be the father, the finding will at least weigh heavily in the ultimate decision in
this case. Thus, we are directing appellant, AAA and her child to submit themselves to deoxyribonucleic
acid (DNA) testing under the aegis of the New Rule on DNA Evidence (the Rules), which took effect on 15
October 2007, subject to guidelines prescribed herein.

WHEREFORE, the instant case is remanded to the RTC for reception of DNA evidence in accordance with
the terms of this Resolution

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