G.R. No.
199270, October 21, 2015 of the truth of such entries, for these are often incomplete and
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. VERGEL
ANCAJAS AND ALLAIN* ANCAJAS, Accused-Appellants.
On October 19, 1998, appellants were charged and convicted with
the crime of Rape for having carnal knowledge with 19 year-old AAA
without the latter’s consent. It appears further that in order to do
so, Vergel Ancajas boxed AAA on the stomach thereby rendering her
unconscious. When AAA regained her consciousness, she noticed
that she was only wearing her t-shirt, her body was in pain, and her
vagina was covered with blood. She then went back to her
employers' house to tell them about the incident. Her employers
then accompanied her to the police station in Bogo, Cebu to report
the rape incident. Said incident was contained in a police blotter.
Notably, a notation of the police blotter reflects that “ xxx the
alleged suspects were Allain Ancajas and Vergel Ancajas and [AAA]
refused (sic) the other suspects.”
Appellants thus contented that if AAA was positive as to their
identification as the perpetrators of the crime charged, why were
there two other names included in the police blotter?
ISSUE: WON the appellants’ argument is meritorious.
HELD: NO.
The inclusion of the two additional names was cured by the sworn
statement of AAA and her categorical declaration in open, court
that appellants were the perpetrators of the crime charged and no
other. Entries in a police blotter, although regularly done in the
course of the performance of official duty, are not conclusive proof
inaccurate. These, therefore, should not be given undue significance
or probative value as to the facts stated therein.
BEST EVIDENCE RULE
REPUBLIC vs. MUPAS
DOTC awarded the construction and development of the NAIA-IPT
III under a build-operate-and-transfer arrangement to Paircargo
Consortium. Later on, the latter organized itself as PIATCO. A
Concession Agreement was then entered with PIATCO where the
latter was to build, operate, and maintain the NAIA-IPT III during the
concession period of 25 years. A series of suits ensued. One of
which is a complaint by the Government for the expropriation of the
NAIA-IPT III. RTC evenutally issued a writ of possession in favor of
the Government.
PIATCO then presented an appraisal of NAIA-IPT’s replacement
costs, including its attendant costs which include photocopies of
numerous documents, and the validation of PIATCO’s computation
of attendant costs prepared by Reyes Tacandong& Co., among
others.
When the case eventually reached the CA, the latter arrived at its
own formula of the NAIA-IPT III’s replacement cost. It likewise
observed that PIATCO’s summarized computation of attendant
costs was self-serving and unsubstantiated by relevant evidence.
PIATCO then argued that its non-submission of original documents
before the trial court is justified under Section 3 (c), Rule 130 of the
ROC.
ISSUE: WON PIATCO’s non-submission of original copies is fatal to
its cause.
Held: YES.
Whenever a party seeks an exemption under the best evidence rule
pursuant to Section 3 (c), Rule 130, he asks permission from the trial
court to produce a summary of numerous documents, whose
originals are available to the adverse party for inspection. He does
not ask permission from the trial court to present in evidence the
numerous non-original documents.
Thus, if a party desires to present photocopies of the original
documents, he must first establish that the presentation of
photocopies is justified under Section 3 (a), (b), and/or (d), Rule 130.
He must establish the presence of all the elements under these
provisions. In this case, however, PIATCO failed to establish that the
photocopied documents fall under Section 3 (a), (b), and/or (d),
Rule 130 of the Rules of Court. These photocopied documents are
hearsay evidence. They are mere scraps of paper and have no
weight as basis for the attendant costs of the NAIA-IPT III.
G.R. No. 191936, June 01, 2016
VIRGINIA D. CALIMAG, Petitioner, v. HEIRS OF SILVESTRA N.
MACAPAZ, REPRESENTED BY ANASTACIO P. MACAPAZ, JR.,
Respondents.
On March 2, 2006, herein respondents, asserting that they are the
heirs of Silvestra Macapaz, instituted an action for Annulment of
Deed of Sale and Cancellation of TCT with Damages against Virginia
Calimag and the Register of Deeds of Makati City. Calimag then
averred that the respondents have no legal capacity to institute said
action on the ground that they are illegitimate children of
Anastacio, Sr. As such, they have no right over Silvestra's estate
pursuant to Article 992, NCC. In order to prove their legitimate
filiation, the respondents presented their respective Certificates of
Live Birth issued by the NSO.
Calimag then contended that said documents do not conclusively
prove the respondents' legitimate filiation since they contain no
entry stating whether the respondents are of legitimate or
illegitimate filiation. Moreover, Calimag argued that the certificates
of live birth were not signed by Anastacio, Sr. She argues that the
birth certificate must be signed by the father in order to be
competent evidence to establish filiation, whether legitimate or
illegitimate.
ISSUE: WON Calimag’s contentions are tenable.
HELD: NO.
"A certificate of live birth is a public document that consists of
entries regarding the facts of birth in the Civil Registry made in the
performance of a duty of the Civil Registrar. Thus, being public
documents, the respondents' certificates of live birth are presumed
valid, and are prima facie evidence of the truth of the facts stated in
them.
The petitioner's assertion that the birth certificate must be signed
by the father in order to be a competent evidence of legitimate
filiation does not find support in law and jurisprudence. Verily,
under Section 5 of Act No. 3753,46 the declaration of either parent
of the new-born legitimate child shall be sufficient for the
registration of his birth in the civil register.

GR No. 202514, Jul 25, 2016

ANNA MARIE L. GUMABON v. PHILIPPINE NATIONAL BANK

On August 12, 2004, Anna Marie filed a complaint for recovery of

sum of money and damages against PNB and the PNB Delta branch
manager Silverio Fernandez. The case stemmed from the PNB's
refusal to release Anna Marie's money in a consolidated savings
account and in two foreign exchange time deposit. PNB argued that
Anna Marie is not entitled to be paid mainly because she already
withdrew and used the funds in her account. The bank presented
photocopied documents to substantiate its claim.

In her reply, Anna Marie argued that the best evidence of her
withdrawals is the withdrawal slips duly signed by her and the
passbooks pertaining to the accounts. PNB, however, failed to show
any of the withdrawal slips and/or passbooks, and also failed to
present sufficient evidence that she used her accounts' funds.

ISSUE: WON PNB’s failure to present the original copies of Anna

Marie’s transactions is fatal to its cause.

HELD: YES.