Sunday, February 15, 2009

VILLAFLOR VS. SUMMERS [41 PHIL 62; G.R. NO. 16444; 8 SEP 1920]



Facts:
Petitioner Villaflor was charged with the crime of adultery. The trial judge ordered the petitioner to subject herself into physical examination to test whether or not she was pregnant to prove the determine the crime of adultery being charged to her. Herein petitioner refused to such physical examination interposing the defense that such examination was a violation of her constitutional rights against self-incrimination.


Issue: Whether or Not the physical examination was a violation of the petitioner’s constitutional rights against self-incrimination.


Held: No. It is not a violation of her constitutional rights. The rule that the constitutional guaranty, that no person shall be compelled in any criminal case to be a witness against himself, is limited to a prohibition against compulsory testimonial self-incrimination. The corollary to the proposition is that, an ocular inspection of the body of the accused is permissible.


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