The Supreme Court held that duplicate originals of documents, such as sales invoices and order slips, are admissible as evidence in Philippine courts, provided they are executed at or about the same time with identical contents. This ruling clarifies the application of the Best Evidence Rule and ensures that parties are not unduly burdened by technical requirements when proving their claims, especially in commercial disputes. The decision emphasizes the importance of substance over form, allowing for a more efficient and equitable resolution of cases. This means businesses can rely on their duplicate records in court, streamlining the process of proving transactions and enforcing agreements.

Proof in Paper: When Are Duplicate Documents as Good as the Original?

Capital Shoes Factory, Ltd. (CSFL), a foreign corporation, sued Traveler Kids, Inc. (TKI), a domestic corporation, for collection of sum of money and damages arising from unpaid purchase orders for children’s shoes and sandals. During trial, CSFL presented sales invoices and order slips to evidence the transactions, but TKI objected, arguing that these were mere photocopies and inadmissible as evidence. The Regional Trial Court (RTC) admitted the exhibits, but the Court of Appeals (CA) partially granted TKI’s petition for certiorari, excluding several exhibits for being photocopies. The Supreme Court (SC) then had to determine whether these duplicate documents were admissible as evidence, as well as consider the scope of the CA’s power to review factual findings of the trial court in a certiorari proceeding. The heart of the legal matter was whether CSFL had sufficiently demonstrated that the exhibits were indeed duplicate originals.

The Supreme Court anchored its decision on Section 4(b), Rule 130 of the Rules of Court, which explicitly states that when a document is produced in two or more copies at or about the same time with identical contents, all such copies are regarded as originals. This rule acknowledges that in modern business practices, documents are often created simultaneously, and each copy carries the same evidentiary weight. The Court referred to the case of Trans-Pacific Industrial Supplies v. The Court of Appeals and Associated Bank, where it had previously stressed that duplicate originals are indeed admissible as evidence.

Sec. 4 . Original of document. —

x x x x

(b) When a document is in two or more copies executed at or about the same time, with identical contents, all such copies are equally regarded as originals.

The Court emphasized that for copies to be considered duplicate originals, they must be produced contemporaneously with identical contents. In the case at hand, the testimony of CSFL’s principal witness, Ms. Susan Chiu, was crucial. She explained that CSFL typically prepared two copies of invoices for each transaction – one for the client and one retained by the company. The Supreme Court highlighted that the transcript of stenographic notes (TSN) showed that Chiu convincingly explained that the documents were not mere photocopies but were in fact, duplicate originals of invoices and order slips.

The Supreme Court critically noted that the Court of Appeals had overlooked crucial details in the RTC records and the TSNs. The Court found that the duplicate originals were, in fact, produced in court and compared with their photocopies during the hearing before the trial court. Furthermore, the transcripts revealed that after the comparison, the photocopies were the ones retained in the records. This procedural detail was pivotal in the SC’s determination that the CA had erred in its assessment.

Building on this point, the Supreme Court also touched on the procedural impropriety of TKI’s immediate resort to a certiorari petition. Instead of presenting its own evidence and then appealing an unfavorable decision, TKI prematurely sought relief from the CA. The Supreme Court cited Johnson Lee v. People of the Philippines, where it was emphasized that even if the admission of evidence is erroneous, it is merely an error of judgment, not of jurisdiction. The proper course of action would have been to present countervailing evidence and appeal the decision if necessary.

In this case, there is no dispute that the RTC had jurisdiction over the cases filed by the public respondent against the petitioner for estafa.  The Order admitting in evidence the photocopies of the charge invoices and checks was issued by the RTC in the exercise of its jurisdiction.  Even if erroneous, the same is a mere error of judgment and not of jurisdiction.  Additionally, the admission of secondary evidence in lieu of the original copies predicated on proof of the offeror of the conditions sine qua non to the admission of the said evidence is a factual issue addressed to the sound discretion of the trial court. Unless grave abuse of discretion amounting to excess or lack of jurisdiction is shown to have been committed by the trial court, the resolution of the trial court admitting secondary evidence must be sustained. The remedy of the petitioner, after the admission of the photocopies of the charge invoices and the checks, was to adduce his evidence, and if after trial, he is convicted, to appeal the decision to the appropriate appellate court.  Moreover, under Rule 45 of the Rules of Court, as amended, only questions of law may be properly raised.

In conclusion, the Supreme Court reversed the Court of Appeals’ decision, reinstating the Regional Trial Court’s order that admitted the exhibits. This decision reinforces the principle that duplicate originals are admissible as evidence, provided they meet the criteria outlined in the Rules of Court. It also serves as a reminder of the proper procedural steps to be taken in challenging evidentiary rulings, emphasizing the importance of allowing trial courts to exercise their discretion within the bounds of the law. This ruling ensures efficiency in court proceedings. It also ensures fairness to parties involved in commercial disputes by giving them the opportunity to prove their claims with records kept in the ordinary course of business.

FAQs

What was the key issue in this case?	The key issue was whether photocopies of sales invoices and order slips presented as evidence were admissible, given the respondent’s claim that they were mere photocopies and not duplicate originals. The Court resolved the issue by determining if the documents met the requirements for duplicate originals as defined by the Rules of Court.
What is a duplicate original?	A duplicate original is a copy of a document that is produced at or about the same time as the original, with identical contents. According to the Rules of Court, all such copies are equally regarded as originals.
What did the Court of Appeals decide?	The Court of Appeals partially granted the respondent’s petition, excluding several exhibits, including the sales invoices and order slips, finding that they were merely photocopies and inadmissible as evidence. They believed that the original documents had not been presented.
How did the Supreme Court rule?	The Supreme Court reversed the Court of Appeals’ decision, ruling that the exhibits were indeed duplicate originals and should be admitted as evidence. They found that the witness’s testimony, supported by the trial records, sufficiently established that the documents were produced at the same time as the originals.
What is the Best Evidence Rule?	The Best Evidence Rule generally requires that the original document be presented as evidence to prove its contents. However, there are exceptions, such as when the original has been lost or destroyed, or when duplicate originals exist.
Why did the Supreme Court emphasize the witness’s testimony?	The Supreme Court emphasized the witness’s testimony because it provided crucial evidence that the documents were prepared as duplicate originals, with one copy for the client and one for the company’s records. This testimony helped establish that the documents met the criteria for admissibility as duplicate originals.
What was the procedural error committed by the respondent?	The respondent prematurely filed a petition for certiorari with the Court of Appeals instead of presenting its own evidence at the trial court level and then appealing any unfavorable decision. This action was deemed an improper shortcut that disrupted the orderly administration of justice.
What is the significance of this ruling?	This ruling clarifies the application of the Best Evidence Rule and reinforces the principle that duplicate originals are admissible as evidence. It ensures that parties can rely on their business records in court, streamlining the process of proving transactions and resolving disputes, especially in commercial litigation.

This case underscores the importance of understanding the nuances of evidentiary rules in Philippine law. By clarifying the admissibility of duplicate originals, the Supreme Court has provided valuable guidance for litigants and legal practitioners alike. The ruling emphasizes the need to examine the specific circumstances surrounding the creation and preservation of documents, and reminds parties to follow proper procedural channels when challenging evidentiary rulings.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: CAPITAL SHOES FACTORY, LTD. VS. TRAVELER KIDS, INC., G.R. No. 200065, September 24, 2014