CASE #1

People v. VallejoG.R. No. 144656,May 9, 2002

1.) In the case at bar, Vallejo was charged with rape with homicide. The prosecution now submitted DNA evidence gathered from the body of the victim which matched the DNA profile of Vallejo. He assailed the DNA analysis, that the DNA samples should be inadmissible because the body and the clothing of Daisy (including his clothing – which in effect is an admission placing him in the crime scene were already soaked in smirchy waters, hence contaminated. The said accused further challenged the validity of the oral and written confessions presented as evidence against him. He alleges that the oral confessions were inadmissible in evidence for being hearsay, while the extrajudicial confessions were obtained through force and intimidation. First, DNA evidence collected from a crime scene can link a suspect to a crime or eliminate one from suspicion in the same principle as fingerprints are used. Incidents involving sexual assault would leave biological evidence such as hair, skin tissue, semen, blood, or saliva which can be left on the victim’s body or at the crime scene. Hair and fiber from clothing, carpets, bedding, or furniture could also be transferred to the victim’s body during the assault. Forensic DNA evidence is helpful in proving that 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. It was in this case, that the first real breakthrough of DNA as admissible and authoritative evidence in Philippine jurisprudence has been accepted in an en banc decision where the rapist (Vallejo) and murder victim’s DNA samples from the bloodstained clothes of the accused were admitted in evidence.

Second, the claim of the accused is untenable. The confession he made, can be likened to one freely and voluntarily given to an ordinary individual and is, therefore, admissible as evidence.

2.) In the said case, the accused (Vallejo) contended that the trial court erred in convicting him of rape with homicide despite the insufficiency and weakness of the circumstantial evidence of the prosecution. He contended further, that the trial court also erred in giving evidentiary weight to the alleged oral confessions of the accused despite its being hearsay in nature and that the said DNA samples were inadmissible as evidence.

I find Vallejo’s contentions to be without merit. I cannot find any errors on the part of the trial court. The error can be manifested on the part of the defense. First, an accused can be convicted provided sufficient circumstantial evidence is presented by the prosecution to prove beyond reasonable doubt that the accused committed the crime. It was stated under Rule 133, section 4 of the Revised Rules on Evidence, circumstantial evidence is sufficient to sustain a conviction if:

“(a) there is more than one circumstance;

“(b) the facts from which the inferences are derived are proven; and

“(c) the combination of all circumstances is such as to produce conviction beyond reasonable doubt.”23

In the case at bar, the prosecution was able to established circumstantial evidence to prove that the accused was guilty beyond reasonable doubt.