7. PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v.

CLAUDIO TEEHANKEE,
JR., Accused-Appellant.

Facts: Accused was charged with the crime of murder for the alleged shooting
incident which took the lives of two persons. Trial court found the accused guilty
beyong reasonable doubt. Hence this appeal.
Issue: Appellant raised the issue of proper identificationof the accused.
Held: where the appellant was convicted of murder on the testimony of three eyewitnesses, we
stated as an obiter dictum that "while eyewitness identification is significant, it is not as accurate
and authoritative as the scientific forms of identification evidence such as the fingerprint or
the DNA test result

8. PEOPLE OF THE PHILIPPINES, Appellee, v. JOEL JANSON and RICKY PINANTAO alias
"OGCO",Appellants.

Facts: The victim admitted that she was not certain of the identity of her perpetrators at the
time of the incident or immediately thereafter. According to her, it was only after Joel Janson was
apprehended for another crime, and after he confessed to the police, that she was able to
confirm her suspicion.
Issue: One of the errors raised is that THE TRIAL COURT ERRED IN FINDING THAT ACCUSEDAPPELLANT JOEL JANSON WAS POSITIVELY IDENTIFIED BY THE PROSECUTION WITNESSES
Held: We find the appeal impressed with merit. After due reflection and deliberation, we still find
difficulty in sustaining the trial courts conclusion regarding appellants guilt because of
inconclusive identification. Doubts persist in our mind as to who are the real malefactors. Yes, a
complex offense has been perpetrated, but who are the perpetrators? How we wish we had DNA
or other scientific evidence to still our doubts! But we have only uncertain testimonies to rely on.

9. ROSENDO HERRERA, Petitioner, v. ROSENDO ALBA, minor, represented by his mother

ARMI A. ALBA, and HON. NIMFA CUESTA-VILCHES, Presiding Judge, Branch 48,
Regional Trial Court, Manila, Respondents.

Facts: Rosendo Alba ("respondent"), represented by his mother Armi Alba, filed before the trial
court a petition for compulsory recognition, support and damages against petitioner. Petitioner
filed his answer with counterclaim where he denied that he is the biological father of respondent.
Petitioner also denied physical contact with respondent's mother. Respondent filed a motion to
direct the taking of DNA paternity testing to abbreviate the proceedings. RTC and CA granted the
motion
Issue: Petitioner raises the issue of whether a DNA test is a valid probative tool in this
jurisdiction to determine filiation.

Held: Yes. 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.
DNA analysis that excludes the putative father from paternity should be conclusive proof
of non-paternity. If the value of Probability of Paternity W is less than 99.9%, the results of the
DNA analysis should be considered as corroborative evidence. If the value of Probability of
Paternity W is 99.9% or higher, then there is refutable presumption of paternity.55 This
refutable presumption of paternity should be subjected to the Vallejo standards.
In assessing the probative value of DNA evidence, therefore, courts should 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.37

10. ARNEL L. AGUSTIN, Petitioner, v. HON. COURT OF APPEALS AND MINOR MARTIN
JOSE PROLLAMANTE, REPRESENTED BY HIS MOTHER/GUARDIAN FE ANGELA
PROLLAMANTE,Respondents.

Facts: Respondents Fe Angela and her son Martin Prollamante sued Martin's alleged biological
father, petitioner Arnel L. Agustin, for support and support pendente lite before the Regional Trial
Court. Arnel opposed said motion by invoking his constitutional right against self-incrimination.
The trial court denied the motion to dismiss the complaint and ordered the parties to submit
themselves to DNA paternity testing at the expense of the applicants. The Court of Appeals
affirmed the trial court.
Issue: whether DNA paternity testing can be ordered in a proceeding for support without
violating petitioner's constitutional right to privacy and right against self-incrimination.
Held: The kernel of the right is not against all compulsion, but against testimonial compulsion.
The right against self-incrimination is simply against the legal process of extracting from the lips
of the accused an admission of guilt. It does not apply where the evidence sought to be excluded
is not an incrimination but as part of object evidence.

11. ESTATE OF ROGELIO G. ONG, Petitioner, v. Minor JOANNE RODJIN DIAZ,

Represented by Her Mother and Guardian, Jinky C. Diaz, Respondent.
Facts: A complaint3 for compulsory recognition with prayer for support pending litigation was filed
by minor Joanne Rodjin Diaz, represented by her mother and guardian, Jinky C. Diaz, against
Rogelio G. Ong. Rtc decided in favor of the plaintiff. Ca REMANDED the case to the court a quo

for the issuance of an order directing the parties to make arrangements for DNA analysis for the
purpose of determining the paternity of plaintiff minor Joanne Rodjin Diaz
Issue: WHETHER OR NOT THE COURT OF APPEALS ERRED WHEN IT REMANDED THE CASE TO
THE COURT A QUO FOR DNA ANALYSIS DESPITE THE FACT THAT IT IS NO LONGER FEASIBLE
DUE TO THE DEATH OF ROGELIO G. ONG.
Held: No. It is obvious to the Court that 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. Under Section 4 of the Rules, the courts are authorized, after
due hearing and notice, motu proprio to order a DNA testing. However, while this Court retains
jurisdiction over the case at bar, capacitated as it is to receive and act on the matter in
controversy, the Supreme Court is not a trier of facts and does not, in the course of daily routine,
conduct hearings. Hence, it would be more appropriate that the case be remanded to the RTC for
reception of evidence in appropriate hearings, with due notice to the parties.

12. PEOPLE OF THE PHILIPPINES, Appellee, v. RUFINO UMANITO, Appellant.

Facts: appellant was charged with the crime of rape. Regional Trial Court found Rufino Umanito
(appellant) guilty beyond reasonable doubt of the crime of rape. Ca affirmed the judgment. In
his appeal, appellant seeks his acquittal on reasonable doubt by reason of the questionable
credibility of AAA with respect to her varying allegations. SC remanded to the RTC for reception
of DNA evidence in accordance with the terms of this Resolution. The RTC is further directed to
report to the Court the results of the proceedings below within sixty (60) days from receipt
hereof.
Issue:

What are the rules on DNA Testing?

Held: The Rule shall not preclude a DNA testing, without need of a prior court order, at the
behest of any party, including law enforcement agencies, before a suit or proceeding is
commenced. If the case is remanded to the RTC for receiving evidence to the DNA test result the
hearing should be confined to ascertaining the feasibility of DNA testing with due regard to the
standards set in Section 4 (a), (b), (c) and (e) of the Rules. It is the RTC which shall determine
the institution36 to undertake the DNA testing and the parties are free to manifest their
comments on the choice of DNA testing center. 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.