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Updated 21st February 2025
Herrera vs. Alba
This case involves a petition for review to set aside the Court of Appeals' decision affirming the trial court's orders directing Rosendo Herrera to undergo DNA paternity testing. The petitioner, Rosendo Herrera, opposed the DNA test, arguing it violated his right against self-incrimination and lacked legal acceptance. The Supreme Court dismissed the petition, affirming the lower courts' decisions and recognizing DNA testing as a valid probative tool in paternity cases.

Primary Holding

DNA paternity testing is a valid and admissible method to establish filiation in paternity suits, provided that proper procedures are followed, and it does not violate the right against self-incrimination.

Background

DNA paternity testing is a valid and admissible method to establish filiation in paternity suits, provided that proper procedures are followed, and it does not violate the right against self-incrimination.

History

  • 14 May 1998: Rosendo Alba filed a petition for compulsory recognition, support, and damages against Rosendo Herrera.

  • 7 August 1998: Herrera filed an answer denying paternity.

  • 3 February 2000: Trial court ordered DNA paternity testing.

  • 8 June 2000: Trial court denied Herrera’s motion for reconsideration.

  • 18 July 2000: Herrera filed a petition for certiorari with the Court of Appeals.

  • 29 November 2000: Court of Appeals affirmed the trial court’s orders.

  • 23 May 2001: Court of Appeals denied Herrera’s motion for reconsideration.

  • 15 June 2005: Supreme Court dismissed Herrera’s petition.

Facts

  • 1. Rosendo Alba, represented by his mother Armi Alba, filed a paternity suit against Rosendo Herrera.
  • 2. Herrera denied paternity and opposed DNA testing, arguing it violated his right against self-incrimination and lacked legal acceptance.
  • 3. The trial court ordered DNA testing, which Herrera contested, leading to appeals up to the Supreme Court.

Arguments of the Petitioners

  • 1. DNA testing violates his right against self-incrimination.
  • 2. DNA testing lacks legal acceptance and reliability.
  • 3. The trial court misapplied the ruling in Lim v. Court of Appeals.
  • 4. The DNA test would be inconclusive and irrelevant.

Arguments of the Respondents

  • 1. DNA testing is a reliable and scientifically accepted method to establish paternity.
  • 2. The right against self-incrimination does not apply to physical evidence like DNA samples.
  • 3. The trial court correctly applied the law in ordering DNA testing.

Issues

  • 1. Is DNA testing a valid probative tool in paternity suits?
  • 2. Does DNA testing violate the right against self-incrimination?
  • 3. What are the conditions for the admissibility of DNA test results in paternity cases?

Ruling

  • 1. The Supreme Court ruled that DNA testing is a valid and admissible method to establish paternity.
  • 2. The right against self-incrimination does not apply to physical evidence like DNA samples.
  • 3. Proper procedures must be followed in conducting DNA tests, and the results must meet a high standard of reliability (99.9% probability of paternity).
  • 4. The Court affirmed the lower courts' decisions, dismissing Herrera’s petition.

Doctrines

  • 1. Right Against Self-Incrimination: Applies only to testimonial evidence, not physical evidence like DNA samples.
  • 2. Admissibility of DNA Evidence: DNA testing is admissible if proper procedures are followed and the results are reliable.
  • 3. Paternity and Filiation: DNA testing can be used to establish filiation, especially in cases involving illegitimate children.

Key Excerpts

  • 1. Right Against Self-Incrimination: Applies only to testimonial evidence, not physical evidence like DNA samples.
  • 2. Admissibility of DNA Evidence: DNA testing is admissible if proper procedures are followed and the results are reliable.
  • 3. Paternity and Filiation: DNA testing can be used to establish filiation, especially in cases involving illegitimate children.

Precedents Cited

  • 1. Lim v. Court of Appeals (270 SCRA 2): Cited by petitioner to argue against the admissibility of DNA testing.
  • 2. People v. Vallejo (431 Phil. 798): Discussed the probative value of DNA evidence and the need for proper procedures.
  • 3. Tijing v. Court of Appeals (354 SCRA 17): Recognized DNA testing as a modern and scientific method for resolving parentage issues.
  • 4. Frye v. U.S. (293 F. 1013): Discussed the general acceptance standard for scientific evidence.
  • 5. Daubert v. Merrell Dow Pharmaceuticals (509 U.S. 579): Modified the Frye standard, focusing on the reliability and relevance of scientific evidence.

Statutory and Constitutional Provisions

  • 1. 1987 Constitution, Article III, Section 17: Right against self-incrimination.
  • 2. Family Code, Articles 165-175: Provisions on paternity and filiation.
  • 3. Rules of Court, Rule 130, Sections 39-40: Evidence on pedigree and family reputation.