UP Law BGC Eve 2024 People v.

Umanito
Criminal Procedure Rules on DNA Evidence
SUMMARY
AAA, aged between 12 and 18 years, was raped by petitioner
Umanito. There were discrepancies in the testimony of AAA but
the lower courts were convinced of her credibility. On the other
hand, Umanito had an alibi and alleges that it was another man
AAA had sexual congress with. The Court decided to apply for
the first time the New Rules on DNA Evidence and remanded
the case to RTC.
2007 Tinga
DOCTRINE
This case is the first to apply the New Rules on DNA Evidence.
Case was simply remanded to RTC to apply the new rules.
Since there are incongruent assertions from both parties, DNA
testing is relevant to determine whether the appellant charged of
rape is the father of the victim’s child.

FACTS

 AAA is female who is over 12 but below 18 years old. In July 1989, 9pm, on her way to her grandmother’s home, Rufino Umanito
accosted her. He waited for her over a creek and pointed a knife to her abdomen. They went to the premises of an elementary
school where he undressed and raped her. It was only 6 months later when her mother noticed the prominence of AAA’s
stomach.
 RTC Bauang, La Union
o Umanito was charged with rape of AAA. He pleaded not guilty.
 He claimed that he was home the whole day. He admitted that he had courted AAA but she spurned him. He
also said that AAA had a crush on him since she frequently visits his house.
o RTC found him guilty with penalty of reclusion perpetua.
 Even if there are discrepancies in AAA’s testimony, it did not impair her credibility.
 RTC rejected his alibi. He was not available to prove it was impossible for him to be at the crime scene.
 CA
o Pursuant to People v. Mateo, case was transferred from SC to CA for intermediate review.
o CA affirmed the RTC decision.
 AAA’s inconsistencies were trivial and inconsequential to impair the credibility.
 SC
o Umanito appeals to SC.
 He asserts that the sexual congress AAA engaged in was with another man, her real lover, who was married to
another woman. He also puts in issue the long delay in filing the complaint.

RATIO

W/N DNA testing is necessary to determine the outcome of this case?

Yes.

 SC noted the many incongruent assertions of both parties. Amid this, 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.
 SC used this case as the first one to be tested under the New Rule on DNA Evidence. (Note: this case was decided in October
26, the rule took effect in October 15, 2007)
 SC cited cases discussing the strong weight and validity of DNA testing:
o Herrera v. Alba (2005): the validity of a DNA test as a probative tool to determine filiation in our jurisdiction was put in
issue.
 When DNA or fingerprint tests are done to identify a suspect in a criminal case, the evidence collected from the
crime scene is compared with the "known" print. If a substantial amount of the identifying features are the
same, the DNA or fingerprint is deemed to be a match. But then, even if only one feature of the DNA or
fingerprint is different, it is deemed not to have come from the suspect.
o People v. Vallejo (2002): discussed the probative value, not admissibility, of DNA evidence. By 2002, there was no
longer any question on the validity of the use of DNA analysis as evidence. The Court moved from the issue of
according "official recognition" to DNA analysis as evidence to the issue of observance of procedures in conducting DNA
analysis.
o Tecson v. COMELEC (2004): in case proof of filiation or paternity would be unlikely to satisfactorily establish or would
be dicult to obtain, DNA testing, which examines genetic codes obtained from body cells of the illegitimate child and any
physical residue of the long dead parent could be resorted to.
 IN THIS CASE:
o The determination of whether appellant is the father of AAA's child, which may be accomplished through DNA
testing, is material to the fair and correct adjudication of the instant appeal.
o It is more appropriate that case be remanded to RTC.
 SC discussed some of the rules:
o Sec. 4: What should be the proper scope of such hearings in the trial court involving DNE testing?
o Sec. 5: Should the RTC find the DNA testing feasible in the case at bar, it shall order the same. It is also the RTC which
shall determine the institution to undertake the DNA testing and the parties are free to manifest their comments on the
choice of DNA testing center.
o Sec. 7 and 8: After the DNA analysis is obtained, it shall be incumbent upon the parties who wish to avail of the same to
offer the results in accordance with the rules of evidence. The RTC, in evaluating the DNA results upon presentation,
shall assess the same as evidence in keeping with Sections 7 and 8 of the Rules. The provisions of the Rules of Court
concerning the appreciation of evidence shall apply suppletorily.
o Sec. 10 and 11: Observe requirements of confidentiality and preservation of DNA evidence.
o In assessing the probative value of DNA evidence, the RTC shall consider, among other things, the following data:
 how the samples were collected
  how they were handled
 the possibility of contamination of the samples
 the procedure followed in analyzing the samples
 whether the proper standards and procedures were followed in
 conducting the tests, and the qualification of the analyst who conducted the tests
o Court a quo must ensure that the proper chain of custody in the handling of the samples submitted by the parties is
adequately borne in the records:
 that the samples are collected by a neutral third party
 that the tested parties are appropriately identified at their sample collection appointments
 that the samples are protected with tamper tape at the collection site
 that all persons in possession thereof at each stage of testing thoroughly inspected the samples for tampering
and explained his role in the custody of the samples and the acts he performed in relation thereto.

FALLO

Case remanded to RTC for receiving DNA evidence.