TITLE: Ilao-Quianay vs.

Mapile
CITATION: 474 SCRA 246, G.R. No. 154087 October 25, 2005
TOPIC: Opinion Rule

FACTS:
In the course of the judicial settlement of X’s estate, Atty. R filed a motion to exclude one parcel of land
since it was already transferred to J during X’s lifetime. The heirs of X filed a case for quieting of title
claiming that signature of X in the the deed of sale in favor of Y was forged. J and the heirs presented
their own handwriting experts whose testimonies were conflicting. The court completely disregarded such
testimonies and ruled that the deed of sale was valid. Can the court be compelled to admit the
testimonies of the handwriting experts?

ANSWER:
No.

Courts are not bound by expert testimonies. The opinion of an expert should be considered by the court in
view of all the facts and circumstances of the case. The problem of the evaluation of expert testimony is
left to the discretion of the trial court whose ruling thereupon is not reviewable in the absence of an abuse
of that discretion.

In this case, the court’s decision to completely disregard the conflicting testimonies is valid. As a notarized
document, the deed of sale has in its favor the presumption of regularity and it carries the evidentiary
weight conferred upon it with respect to its due execution.
TITLE: People vs. Umanito
CITATION: 537 SCRA 552, G.R. No. 172607 October 26, 2007
TOPIC: Opinion Rule; Rule on DNA testing

FACTS:
X was criminally charged for raping Y who later on bore a child as a result of the purported rape. The
court directed X, Y and her child to submit themselves to DNA testing under the New Rule on DNA
Evidence. If he is found not to be the father, the finding will at least weigh heavily in the ultimate decision
in the case. Is the court’s order valid?

ANSWER:
Yes.

Under §4 of the New Rule on DNA Evidence, the courts are authorized, after due hearing and notice,
motu proprio to order a DNA testing. DNA print or identification technology is recognized as a uniquely
effective means to link a suspect to a crime, or to absolve one erroneously accused, where biological
evidence is available.

In this case, the determination of whether X is the father of Y’s child, which may be accomplished through
DNA testing, is material to the fair and correct adjudication of the case for rape.
TITLE: People vs. Yatar
CITATION: 428 SCRA 504, G.R. No. 150224 May 19, 2004
TOPIC: Opinion Rule; Rule on DNA testing

FACTS:
X was charged with Rape With Homicide. Subsequent testing showed that the DNA of the sperm
specimen from the vagina of the victim was identical semen to be that of X’s gene type. In an attempt to
exclude the DNA evidence, X contends that the DNA tests were conducted in violation of his right to
remain silent as well as his right against self-incrimination. Is the result of the DNA admissible?

ANSWER:
Yes.

Case law provides that a person’s DNA is the same in each cell and it does not change throughout a
person’s lifetime. Forensic DNA evidence is helpful in proving there was physical contact between an
assailant and a victim. If properly collected from the victim, crime scene or assailant, DNA can be
compared with known samples to place the suspect at the scene of the crime.

The kernel of the right against self-incrimination is not against all compulsion, but against testimonial
compulsion. The right 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.