Villaflor Vs Summers - Digest
Villaflor Vs Summers - Digest
Facts:
Petitioner Villaflor was charged with the crime of adultery. The trial court, upon
motion of the assistant fiscal, ordered her to submit to physical examination to
determine if she was pregnant or not. Villaflor refused to obey the order on the
ground that such examination of her person was a violation of the constitutional
provision relating to self-incrimination. Thereupon she was found in contempt of
court and was ordered to be committed to Bilibid Prison until she should permit
the medical examination required by the court.
Issue:
Held:
No. 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.
Perhaps the best way to test the correctness of our position is to go back once
more to elements and ponder on what is the prime purpose of a criminal trial. As
we view it, the object of having criminal laws is to purge the community of
persons who violate the laws to the great prejudice of their fellow men. Criminal
procedure, the rules of evidence, and constitutional provisions, are then
provided, not to protect the guilty but to protect the innocent. No rule is intended
to be so rigid as to embarrass the administration of justice in its endeavor to
ascertain the truth. No accused person should be afraid of the use of any method
which will tend to establish the truth. For instance, under the facts before us, to
use torture to make the defendant admit her guilt might only result in including
her to tell a falsehood. But no evidence of physical facts can for any substantial
reason be held to be detrimental to the accused except in so far as the truth is to
be avoided in order to acquit a guilty person. (Villaflor vs. Summers, G.R. No.
16444, September 8, 1920)