In Re: The Writ of Habeas Corpus For Reynaldo de Villa (2004) - G.R. 158802 - November 17, 2004 - Ponente: Ynares - Santiago, .J

In Re: The Writ of Habeas Corpus for Reynaldo De Villa (2004) | G.R.
158802 | November
17, 2004 | Ponente: Ynares - Santiago, .J.
Nature of Case: Commander-in-chief Powers

Petitioners: June De Villa
Respondents: The Director, New Bilibid Prison
Summary: Reynaldo De Villa was convicted of rape in 2001. Three years after, his son
alleges that due to newly discovered DNA evidence that proves Reynaldo is NOT the father of
the child born out of the alleged rape, a new trial should be conducted through a petition for
habeas corpus. The court denied the petition for not meeting the criteria of newly discovered
evidence that would merit a retrial.
FACTS:
- Feb 2001: Reynaldo de Villa (67 years old) was found guilty of raping his niece, Aileen
Mendoza (12 years old) and was sentenced with reclusion perpetua. Reynaldo was
ordered to pay support for Leahlyn Corales Mendoza, the child born out of the rape.
- 2004: June de Villa, son of Reynaldo and Petitioner-relator, claimed that during the trial
of the case he was unaware that it was possible to get a DNA test of the child to
determine if Reynaldo was indeed the father of the child.
- Before Reynaldo was convicted by final judgement, June was able to get DNA testing
conducted by National Science Research Institute to prove that Leahlyn could not be
Reynaldo’s child.
- Petitioners proceed to this petition for habeas corpus since Reynaldo is not the father,
they should conduct a new trial with the new DNA evidence as proof of his innocence.
- The petition for Habeas Corpus is used to COLLATERALLY attack the 2001 decision
ISSUES + RULING
WON petition for writ of Habeas Corpus is appropriate to release Reynaldo? No

- The issuance of the writ of Habeas Corpus is mainly provided for those seeking relief
from illegal deprivation of movement. The writ does not apply to scenarios in which the
individual is restrained for a lawful purpose or due to a legal process.
- The extraordinary remedy broadly applies to “all cases of illegal confinement or detention
by which a person has been deprived of his liberty, or by which rightful custody of any
person has been withheld from the person entitled thereto”
- The writ as a POST-CONVICTION REMEDY has limited availability. It applies in the
following scenarios:
a. There has been a deprivation of a constitutional right resulting in the restraint of a
person
b. The court had no jurisdiction to impose the sentence
c. An excessive penalty has been imposed, as such sentence is void as to such
excess
- The writ cannot be used to question the judgement of a competent court which has
jurisdiction over the case
- The petitioner in this case is asking for a retrial and reexamination of the case in light of
the new evidence presented but the writ, although allowed to collaterally attack a courts
jurisdiction, cannot be be used to extend the inquiry to mere errors of the trial court.
- The petitioner has not alleged any denial of a constitutional right.
- Petitioner assails that he had an incompetent counsel and thus was denied effective aid
of counsel. The court dismisses this as the petitioner fails to show how his counsel
committed such negligence that would result in a jurisdictional defect.
WON Reynaldo is entitled to a new trial? No
- Revised Rules of Criminal Proceedure:

Sec 2 of Rule 121 GROUNDS FOR NEW TRIAL
A) Errors of law or irregularities prejudicial to the substantial rights of the accused have been committed
during the trial
B) That new and material evidence has been discovered which the accused could not with reasonable
diligence have discovered and produced at the trial and which if introduced and admitted would probably
change the judgment
- The court does not see that how the DNA evidence can be considered “newly
discovered evidence”
- For a motion for new trial, the evidence must meet the requisites
- Evidence was discovered after the trial
- Evidence COULD NOT HAVE been discovered and produced at the time of the
trial with the exercise of reasonable diligence
- The it is material
- That is carries such weight that could potentially change the judgement
- Since petitioner was simply “unaware” that the test existed, it carries no weight in court.
- The negligence of the petitioner is binding and is not a reason for retrial.
- Even if it was permitted, paternity is not the main issue in rape and does not dismiss the
fact that petitioner was found guilty of such rape.
FINAL RULING
Instant Petition for Habeas Corpus and new trial is DISMISSED.

In Re: The Writ of Habeas Corpus For Reynaldo de Villa (2004) - G.R. 158802 - November 17, 2004 - Ponente: Ynares - Santiago, .J

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In Re: The Writ of Habeas Corpus for Reynaldo De Villa (2004) | G.R.

Nature of Case: Commander-in-chief Powers

WON petition for writ of Habeas Corpus is appropriate to release Reynaldo? No

WON Reynaldo is entitled to a new trial? No

- Revised Rules of Criminal Proceedure:

Instant Petition for Habeas Corpus and new trial is DISMISSED.

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