A paraffin test has been held to be highly unreliable.

The Court thus once

held:
Scientific experts concur in the view that the paraffin test has ".
. . proved extremely unreliable in use. The only thing that it can
definitely establish is the presence or absence of nitrates or nitrites on
the hand. It cannot be established from this test alone that the source
of the nitrates or nitrites was the discharge of a firearm. The person
may have handled one or more of a number of substances which give
the same positive reaction for nitrates or nitrites, such as explosives,
fireworks, fertilizers, pharmaceuticals, and leguminous plants such as
peas, beans, and alfalfa. A person who uses tobacco may also have
nitrate or nitrite deposits on his hands since these substances are
present in the products of combustion of tobacco." In numerous
rulings, we have also recognized several factors which may bring
about the absence of gunpowder nitrates on the hands of a gunman,
viz.: when the assailant washes his hands after firing the gun, wears
gloves at the time of the shooting, or if the direction of a strong wind
is against the gunman at the time of firing. . People v. Teehankee, Jr.,
G.R. Nos. 111206-08, 6 October 1995, 249 SCRA 54, 103.||| as cited
(Revita v. People, G.R. No. 177564, [October 31, 2008], 591 PHIL 340-
356)

Indeed, paraffin tests, in general, have been rendered

inconclusive by this Court. Scientific experts concur in the view that
the paraffin test has proved extremely unreliable. It can only establish
the presence or absence of nitrates or nitrites on the hand; still, the
test alone cannot determine whether the source of the nitrates or
nitrites was the discharge of a firearm. The presence of nitrates should
be taken only as an indication of a possibility or even of a probability
but not of infallibility that a person has fired a gun. 20 Conversely, the
absence of gunpowder nitrates on petitioner's hands, the day after the
incident, does not conclusively establish that he did not fire a gun;
neither are the negative results yielded by the paraffin test an
insurmountable proof of his innocence.||| (Ilisan y Piabol v. People,
G.R. No. 179487, [November 15, 2010], 649 PHIL 151-164)
Appellant likewise capitalizes on the results of the paraffin test
showing that both his hands yielded no trace of gunpowder residue.
Unfortunately for appellant, the results of the paraffin test would not
exculpate him. The negative findings of said test do not conclusively
show that a person did not discharge a firearm at the time the crime
was committed. This Court has observed that it is quite possible for a
person to discharge a firearm and yet exhibit no trace of nitrates:
 when, e.g., the assailant fired the weapon while wearing gloves or
where the assailant thoroughly washes his hands thereafter. 14 As
George de Lara of the NBI stated in his testimony before the trial
court, if a person applies cosmetics on his hands before the cast is
taken, gunpowder residue would not be found in that person's hands.
He also testified that certain factors could contribute to the negative
result of a paraffin test such as perspiration, humidity or the type of
firearm used. In fine, a finding that the paraffin test on the person of
the appellant yielded negative results is not conclusive evidence to
show that he indeed had not fired a gun. ||| (People v. Cabbab, Jr.,
G.R. No. 173479, [July 12, 2007], 554 PHIL 459-477)

Accused-appellants were subjected to paraffin tests on July 20, 2006 at 11:05

a.m. or the very next day and a little over 14 hours after the shooting incident.
Since gunpowder nitrates stay for 72 hours in the hands of a person who fired a
handgun, a timely paraffin test, if positive, will definitely prove that a person had
fired a handgun within that time frame. A negative result, however, does not merit
conclusive proof that a person had not fired a handgun. Thus, the negative paraffin
test results of accused-appellants cannot exculpate them, particularly Tomas, Sr.,
from the crime.
Time and again this Court had reiterated that "even negative findings of the
paraffin test do not conclusively show that a person did not fire a gun," 20 and that
"a paraffin test has been held to be highly unreliable." 21 This is so since there are
many ways, either deliberately or accidentally, that the residue of gunpowder
nitrates in the hands of a person who fired a handgun can be removed. This point
was aptly explained and clarified by defense witness P/Supt. Babor, a Forensic
Chemist and the Regional Chief of the PNP Crime Laboratory at Camp Olivas in San
Fernando, Pampanga. She explained in open court the various factors affecting the
non-adhesion, disappearance or removal of the residue of gunpowder nitrates on
the hands of a person who fires a gun, like the wind direction and velocity when the
handgun was fired, the type of firearm used, the humidity or moisture present in the
ammunition, and when the person wears gloves to preclude adhesion of the
gunpowder nitrates. 22 Also, she explained that opening the pores of the skin will
make the nitrates slough off or disappear and this could be done by subjecting the
hands to heat, like steam from boiling water, or sufficiently washing the hands with
warm water. Finally, gunpowder nitrates are also dissolved by diphenylamine. 23
SIDTCa
||| (People v. Tomas, Sr., G.R. No. 192251, [February 16,
2011], 658 PHIL 653-682)
 It is true that a negative finding in a paraffin test is not a
conclusive proof that one has not fired a gun, as held by this Court in
People v. Pagal 74 and People v. Teehankee 75 which were cited by
the CA in its Decision, since it is possible for a person to fire a gun and
yet bear no traces of nitrate or gunpowder as when the hands are
bathed in perspiration or washed afterwards. 76 Such principle,
however, has no bearing in the present case. In the Pagal and
Teehankee cases, the Court concluded that a negative finding does not
prove that the accused therein had not fired a gun because the
accused were positively identified by witnesses as having shot their
victims, unlike in the case at hand where Galvez is not positively
identified by direct or circumstantial evidence that he shot Enojarda. If
the principle should be given any weight at all, it should be in favor of
Galvez, that is, considering that he is not positively identified, then, the
negative results of the paraffin test bolster his claim that he did not
shoot Enojarda, and not the other way around. ||| (People v. Galvez,
G.R. No. 157221, [March 30, 2007], 548 PHIL 436-489)

n addition, it said that a paraffin test is not a conclusive proof

that a person has not fired a gun and is inconsequential when there is
a positive identification of petitioner. 35 ||| (Escamilla y Jugo v.
People, G.R. No. 188551, [February 27, 2013], 705 PHIL 188-200)

Police Inspector Maria Leonora Chua-Camarao 59 testified that she was the
one who conducted the examination proper of the paraffin casts taken from Robert
Buduhan, Rudy Buduhan, Boyet Ginyang and Boy Guinhicna. She likewise brought
before the trial court the original Letter Request 60 of the Maddela Police Station for
the conduct of paraffin casting; the Letter of Request 61 addressed to the Officer-
in-Charge the PNP Crime Laboratory in Region 2 for the conduct of paraffin
examination; and the paraffin casts of subjects Rudy, Ginyang, Guinhicna and
Robert. 62 Police Inspector Chua-Camarao explained that the purpose of conducting
a paraffin test was to determine the presence of gunpowder residue in the hands of
a person through extraction using paraffin wax. The process involves two stages:
first, the paraffin casting, in which the hands of the subject are covered with
paraffin wax to extract gunpowder residue; and second, the paraffin examination
per se, which refers to the actual chemical examination to determine whether or not
gunpowder residue has indeed been extracted. For the second stage, the method
used is the diphenyl amine test, wherein the diphenyl amine agent is poured on the
paraffin casts of the subject's hands. In this test, a positive result occurs when blue
specks are produced in the paraffin casts, which then indicates the presence of
gunpowder residue. When no such reaction takes place, the result is negative.
SAEHaC
The findings and conclusion on the paraffin test that Police Inspector Chua-
Camarao conducted were contained in Physical Science Report No. C-25-98 63
which yielded a negative result for all the four accused. Nonetheless, the forensic
chemist pointed out that the paraffin test is merely a corroborative evidence, neither
proving nor disproving that a person did indeed fire a gun. The positive or negative
results of the test can be influenced by certain factors, such as the wearing of
gloves by the subject, perspiration of the hands, wind direction, wind velocity,
humidity, climate conditions, the length of the barrel of the firearm or the open or
closed trigger guard of the firearm. 64
||| (People v. Buduhan y Bullan, G.R. No. 178196, [August 6,
2008], 583 PHIL 331-366)