Herrera v. Alba

Summary

This landmark case established the legal framework for DNA paternity testing in the Philippines. A 13-year-old child sought compulsory recognition and support from alleged father Rosendo Herrera, who denied paternity. The trial court ordered DNA testing despite petitioner's objections based on reliability concerns and constitutional rights. The Supreme Court affirmed, ruling that DNA evidence is admissible under Philippine evidence rules when relevant to the issue. The Court established that DNA testing does not violate the right against self-incrimination, which applies only to testimonial evidence. Significantly, the decision set strict standards for DNA evidence: exclusion results are conclusive proof of non-paternity, while inclusion requires minimum 99.9% Probability of Paternity for presumption of paternity. The case marked a shift from wariness about DNA evidence to full acceptance as probative scientific evidence, establishing guidelines for collection, handling, analysis procedures, and analyst qualifications that courts must consider in assessing probative value.