GR 158802; (November, 2004) (Digest)
G.R. No. 158802 , November 17, 2004
June de Villa, petitioner-relator, vs. The Director, New Bilibid Prisons, respondent.
FACTS
Reynaldo de Villa was convicted of the rape of his 12-year-old niece, Aileen Mendoza, and sentenced to reclusion perpetua. The conviction was affirmed by the Supreme Court in a final and executory Decision dated February 1, 2001. The prosecution established that the rape resulted in the birth of a child, Leahlyn Mendoza. Reynaldo is currently detained at the New Bilibid Prison. His son, June de Villa, filed the present petition for a writ of habeas corpus, seeking to justify the continued imprisonment and to secure a new trial. The petition is anchored on a privately obtained DNA test report, which allegedly excludes Reynaldo as the biological father of Leahlyn. This evidence was gathered post-conviction without court order, with samples surreptitiously collected from the child and other relatives.
ISSUE
Whether a writ of habeas corpus is the proper remedy to challenge a final judgment of conviction based on newly discovered evidence, specifically a privately procured DNA test result.
RULING
No. The Supreme Court denied the petition. Habeas corpus is an extraordinary writ designed to inquire into the legality of a person’s detention. It is not a substitute for appeal or a remedy for correcting errors of judgment. The Court emphasized that the writ cannot be used to collaterally attack a final and executory judgment, which in this case had already withstood automatic review. The proper remedy for introducing newly discovered evidence like the DNA report would have been a petition for new trial under Rule 121 of the Rules of Court, which must be filed before the judgment becomes final. The petitioner’s failure to avail of this remedy in a timely manner, and his attempt to introduce evidence gathered through questionable means without court sanction, rendered the habeas corpus petition improper. The legality of Reynaldo de Villa’s detention, based on a valid and final conviction, remains unquestioned. The Court further noted that the integrity and chain of custody of the DNA samples were highly suspect, as they were obtained without consent or judicial oversight, thus diminishing their evidentiary value. The writ of habeas corpus cannot be used to reopen a case already closed with finality.