FACTS:

The case involves a complaint for support filed against the petitioner by the respondents, Fe Angela and her son Martin Prollamante. Fe alleged that she and the petitioner had a relationship and that he fathered Martin. The petitioner denied being Martin's father and opposed the motion for DNA paternity testing. The trial court denied the motion to dismiss and ordered DNA testing, which was affirmed by the Court of Appeals.

The private respondents claimed that Fe had a relationship with the petitioner and that he fathered Martin. The petitioner admitted to having a sexual relationship with Fe but denied being Martin's father. He argued that the complaint for support was converted into a petition for recognition, which is supposedly prohibited by law. The court, however, found the petitioner's arguments without merit and upheld the integration of an action for recognition with an action for support.

The case involves a dispute over the paternity of a child. The petitioner sought to nullify the declaration of filiation and denied being the biological father, while the respondent insisted that he was the father and sought support for the child. The petitioner argued against the use of DNA testing as conclusive evidence of paternity, citing violations of his right to privacy and right against self-incrimination. The court provided a historical background on the recognition of DNA testing in Philippine jurisprudence, stating that it has been recognized as admissible and authoritative evidence since 2002.

In a separate case involving rape, the court recognized the strong weight of DNA testing and affirmed its admissibility. The court emphasized the importance of considering factors such as sample collection, handling, possible contamination, and the qualifications of the analyst in assessing the probative value of DNA evidence. In the present case, an expert witness testified that DNA samples matched the petitioner's gene types.

In the appellant's rape case, evidence was presented showing that the semen found in the victim's vaginal canal matched the appellant's blood sample given in open court. The court acknowledged the value of advances in science and technology in the criminal justice system and referred to the prevailing doctrine in the United States, which allows the use of scientifically valid evidence as long as it is relevant and reliable.

ISSUES:

1. Whether DNA evidence is admissible in court.

2. Whether the DNA evidence presented in this case is reliable and relevant.

3. Whether DNA testing can be ordered by the court in cases involving paternity disputes.

4. Whether the results of DNA testing are admissible as evidence.

5. Whether DNA tests can be used as evidence to prove paternity.

6. Who bears the cost of the DNA test.

7. Whether DNA test results can rebut the presumption of paternity in cases involving child support and visitation.

8. Whether default judgments of paternity can be vacated based on DNA test results.

9. Whether child support and visitation orders can be modified based on DNA test results.

10. Whether the Court of Appeals committed grave abuse of discretion in promulgating its decision and resolution.

RULING:

1. Yes, DNA evidence is admissible in court.

2. Yes, the DNA evidence presented in this case is reliable and relevant.

3. Yes, DNA testing can be ordered by the court in cases involving paternity disputes. Under Section 516-a(b) of the New York Family Court Act, a party may challenge an acknowledgment of paternity and the court shall order genetic marker tests or DNA tests to determine the child's paternity.

4. Yes, the results of DNA testing are admissible as evidence. According to Section 532(a) of the New York Family Court Act, the court shall order genetic marker or DNA tests of a type generally acknowledged as reliable by an accreditation body to aid in the determination of whether the alleged father is the father of the child. The record or report of the results of such tests shall be received in evidence by the court.

5. DNA tests can be used as evidence to prove paternity. A DNA test report or record can be admitted in court as evidence, and if there is at least a 95 percent probability of paternity, such report or record creates a rebuttable presumption of paternity (Family Court Act, Section 532).

6. The initial cost of the DNA test is to be paid by the moving party. However, if the moving party is financially unable to pay, the court may direct a qualified public health officer to conduct the test, or payment may be made from the funds of the appropriate local social services district. The court also has the power to apportion the cost of the test between the parties according to their respective abilities to pay or assess it against the party who does not prevail on the issue of paternity, unless that party is financially unable to pay (Family Court Act, Section 532).

7. Yes, DNA test results showing non-paternity can rebut the presumption of paternity. In Rafferty v. Perkins, the Supreme Court of Mississippi held that DNA test results are sufficient to overthrow the presumption of legitimacy of a child born during the course of a marriage.

8. Yes, default judgments of paternity can be vacated if DNA testing establishes non-paternity. In Kohl v. Amundson, the Supreme Court of South Dakota ruled that even default judgments can be vacated if DNA testing proves non-paternity.

9. Yes, child support and visitation orders can be modified based on DNA test results. In M.A.S. v. Mississippi Dept. of Human Services and Williams v. Williams, the Supreme Court of Mississippi held that even if paternity was established through an earlier agreed order of filiation, child support and visitation orders can be vacated once DNA testing establishes someone other than the named individual to be the biological father.

10. The Court of Appeals did not commit grave abuse of discretion and acted within its jurisdiction in promulgating its decision and resolution. Any error made would have only been an error in judgment. Therefore, the decision of the Court of Appeals, being firmly anchored in law and jurisprudence, was correct.

PRINCIPLES:

• In assessing the probative value of DNA evidence, courts should consider factors such as how the samples were collected and handled, the possibility of contamination, the procedure followed in analyzing the samples, and the qualification of the analyst who conducted the tests.

• The Daubert test, which allows the introduction of new scientific techniques in court as long as they are based on scientifically valid principles and are relevant and reliable, is applicable.

• Compulsory DNA testing and the admissibility of the results thereof have been upheld as constitutional.

• The right against self-incrimination does not apply to object evidence and does not bar the use of DNA testing and its results.

• The right to privacy does not prevent incursions into individual privacy when they are accompanied by proper safeguards that enhance public service and the common good.

• DNA testing is commonly accepted and can be ordered by the court in paternity disputes.

• The results of DNA testing are admissible as evidence if the testing method is generally acknowledged as reliable.

• DNA tests can be used as strong evidence to determine paternity with a high level of accuracy.

• The cost of DNA testing may be borne by either the moving party or the court, depending on the financial capacity of the parties involved.

• DNA test results can rebut the presumption of paternity.

• Default judgments of paternity can be vacated based on DNA test results.

• Child support and visitation orders can be modified based on DNA test results.

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