VILLAFLOR VS.

SUMMERS (SEPTEMBER 8, 1920)

Facts: Petitioner Villaflor was charged with the crime of adultery. The trial judge ordered
the petitioner to subject herself into physicalexamination 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
suchexamination was a violation of her constitutional rights against self-incrimination.
Issue: Whether or Not the physical examination was
petitioners constitutional rights against self-incrimination.

violation

of

the

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 prohibitionagainst compulsory testimonial selfincrimination. The corollary to the proposition is that, an ocular inspection of the body
of the accused is permissible.