CASE #1

People v. Vallejo
G.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 victims body or at the
crime scene. Hair and fiber from clothing, carpets, bedding, or
furniture could also be transferred to the victims 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 victims 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 Vallejos 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.