1.Reyes v. Sotero, G.R. No.
167405, February 16, 2006
Respondent filed a petition for the issuance of letters of administration and settlement of estate
of the late Lising. Reyes filed an Opposition to the petition, claiming that she was an adopted child of
Lising and the latter’s husband and asserting that the petition be dismissed. Petitioner filed a Supplement
to the Opposition attaching thereto the certification of her adoption from the local civil registrar’s office that
the adoption decree was registered therein and also a copy of a Judicial Form and a certification issued
by the clerk of court that the decree was on file in the General Docket of the RTC-Tarlac.
ISSUE: Whether or not petitioner had to prove the validity of her adoption due to imputations of
irregularities
RULING: No. Petitioner need not prove her legal adoption by any evidence other than those which she
had already presented before the trial court. An adoption decree is a public document required by law to
be entered into public records, the official repository of which, as well as all other judicial pronouncements
affecting the status of individuals, is the local civil registrar’s office as well as the court which rendered the
judgment.
2.Republic v. Galeno, G.R. No. 215009, January 23, 2017
On September 2, 2003, respondent filed a petition for correction of the area of Lot before RTC.
Respondent alleged that when she and her co-owners had the subject property resurveyed for the
purpose of partition,The RTC granted the petition upon a finding that respondent was able to substantiate
the allegations in her petition to warrant a correction of the area of the subject property. Hence, it directed
the Register of Deeds of the Province of Iloilo to correct such area in OCT No. 46417 from 20,948 to
21,298 square meters.
ISSUE: Whether or not the documentary evidence presented before the trial court can be accorded
probative weight
RULING: No.
The documentary evidence is not sufficient to warrant the correction prayed for. The Court cannot accord
probative weight upon them in view of the fact that the public officers who issued the same did not testify
in court to prove the facts stated therein.
3.Teoco v. Metropolitan Bank and Trust Company, G.R. No. 162333, December 23, 2008
FACTS:
ISSUE:
Whether or not the assignment of right of redemption is admissible in evidence as a public
document?
HELD:
Documents consisting of entries in public records made in the performance of a duty by a public officer
are prima facie evidence of the facts therein stated. All other public documents are evidence, even
against a third person, of the fact which gave rise to their execution and of the date of the latter.
4. Nedlloyd Lijnen B.V. Rotterdam v. Glow Laks Enterprises, Ltd., G.R. No. 156330, November 19, 2014
FACTS:
Respondent filed a claim against petitioner when the goods the latter were supposed to deliver
were unlawfully claimed by unauthorized third persons who have forged the bill of ladings which
represented said goods and hence constituting misdelivery. Both parties offered testimonial and
documentary evidence to support their respective causes. The RTC rendered a Decision ordering
the dismissal of the complaint but granted petitioners’ counterclaims.
ISSUE:
Whether petitioners were able to prove the laws of panama by presenting as evidence the [Gaceta]
official of Republica de Panama no. 17.596 where the applicable Panamanian laws were officially
published, and the testimony of expert witnesses.
HELD:
In order for a foreign statute to be taken judicial notice of and admitted into evidence, a copy of
said statute must be offered in evidence with an attestation by the proper legal officer of the
foreign state and a certificate by the foreign relations officer of said state.
5. Raz v. Intermediate Appellate Court, G.R. No. 73010, April 27, 1990
FACTS:
A Conditional Assignment of Rights and Interests over a Foreclosure Judgment was entered into between
petitioner Reva Raz and Encarnacion Villanueva. The petitioner filed a complaint for specific
performance and damages, claiming that the respondent had reneged on her duty to deliver the property
to the assignee in accordance with their agreement. In her answer, Villanueva alleged that it was the
petitioner who had defaulted in her payments and thus given just cause for the rescission of the
agreement. To support her claim, Villanueva presented two letters she said she had sent Raz.
ISSUE: Whether or not the two letters allegedly sent by the private respondent are admissible in
evidence.
Held:
Evidence respecting the handwriting may also be given by a comparison, made by the witness or the
court, with writings admitted or treated as genuine by the party against whom the evidence is offered or
proved to be genuine to the satisfaction of the judge.
6. Progressive Trade & Service Enterprises v. Antonio, G.R. No. 179502, September 18, 2009
FACTS:
Cebrero, owner, sold the land to Progressive Trade and Services (Progressive). Maria Milagrosa Antonio
(Milagrosa) filed a Complaint claiming that the land was sold to her by Cebrero spouses only that she was
not able to register because she had to attend to personal family matters abroad. Progressive claimed
that it bought the land in good faith while Secundina denied the said sale to Milagrosa.RTC found that
Secundina failed to prove her allegation that the Deed was a forgery because she failed to present expert
witnesses.
ISSUE: WON expert’s testimony is required in examining handwritings or signatures.
HELD:
No, it is settled that handwriting experts, while useful, are not indispensable in examining or comparing
handwritings or signatures.
Section 22 of Rule 132 states: The handwriting of a person may be proved by any witness who believes
it to be the handwriting of the person because he has seen the person write, or has seen writing
purporting to be his upon which the witness has acted or been charged, and has thus acquired knowledge
of the handwriting of such person.
7.Aldemita v. Silva, G.R. No. 166403
FACTS: A complaint for Quieting of Title was filed by respondents with RTC, Cebu. Aldemita filed a
verified answer. The parties made the stipulations that: (1) Aldemita admitted that a lot in Cebu has been
registered in the name of Melquiades Silva with a tax declaration also in Silva’s name; and (3) Almedita
admitted, too, that a document which was purportedly executed by Sila in favor of De Zabate involving the
land in question is actually a forged document.
ISSUE: WON the CA seriously erred & xgravely abused its discretion when it ruled as null and void and
without force and effect the documents purportedly executed by M. Silva in favor of de Zabate.
HELD:
NO. An ancient document is one that is (1) more than 30 years old, (2) found in the proper custody, and
(3) unblemished by any alteration or by any circumstance of suspicion. It must on its face appear to be
genuine. Where a private document is more than thirty years old, is produced from a custody in which it
would naturally be found if genuine, and is unblemished by any alterations or circumstances of suspicion,
no other evidence of its authenticity need be given.
8. Dycoco v. Orina, G.R. No. 184843, July 30, 2010
FACTS:
Dycoco, represented by his attorneys-in-fact, filed a complaint for annulment of the REM and transfer
certificate of title with damages, against Adelaida and her husband and claimed that Dycoco's signature
on the REM was forged, to prove which they presented various documents that Dycoco was working in
the United States of America as a licensed physician. They also presented Dycoco's U.S. Passport,
personal checks maintaining the due execution of the REM, presented Evelyn who testified on a
photocopy of the REM.
ISSUE: Whether a mere photocopy of the mortgage is admissible?
Held:
No. Since the REM is not a public document, it is subject to the requirement of proof for private
documents. It was thus incumbent upon Adelaida to prove that Dycoco's signature is genuine. As stated
earlier, a mere photocopy of the REM was presented. It is axiomatic that when the genuineness of
signatures on a document is sought to be proved or disproved through comparison of standard
signatures with the questioned signature, the original thereof must be presented.
9. Patula v. People, G.R. No. 164457, April 11, 2012
FACTS:
AN information was filed charging PATULA of having collected and received the total sum of P
131,286.97 from several customers of said company but has failed to remit the said amount to the
company despite the repeated demands. However, during Guivencan’s direct-examination, petitioner’s
counsel continuously objected and questioned the pieces of evidence and testimony of Guivencan on the
ground that they were hearsay because the persons who actually made the entries were not themselves
presented in court.
HELD:
The requirement of authentication of a private document is excused only in four instances, specifically: (a)
when the document is an ancient one within the context of Section 21, Rule 132 of the Rules of Court;(b)
when the genuineness and authenticity of an actionable document have not been specifically denied
under oath by the adverse party; (c) when the genuineness and authenticity of the document have been
admitted; or (d) when the document is not being offered as genuine.
10.
Iwasawa v. Gangan, G.R. No. 204169, September 11, 2013
Facts:
Petitioner, a Japanese national, met private respondent introduced herself as "single" and "has never
married before. Petitioner married a private respondent. After the wedding, the couple resided in
Japan.Petitioner noticed his wife become depressed. He confronted his wife about it. To his shock,
private respondent confessed to him that she received news that her previous husband passed away.
Petitioner sought to confirm the truth of his wife’s confession and discovered that indeed, she was
married. This prompted petitioner to file a petition for the declaration of his marriage to private respondent
as null and void
ISSUE:
Whether the testimony of the NSO records custodian was necessary before they could be accorded
evidentiary weight.
RULING:
NO. As public documents, they are admissible in evidence even without further proof of their due
execution and genuineness. Moreover, not only are said documents admissible, they deserve to be given
evidentiary weight because they constitute prima facie evidence of the facts stated therein. And in the
instant case, the facts stated therein remain unrebutted since neither the private respondent nor the
public prosecutor presented evidence to the contrary.
11.
Republic v. Spouses Gimenez, G.R. No. 174673, January 11, 2016
The Complaint seeks to recover ill-gotten wealth allegedly acquired by them as dummies, agents,
or nominees of Marcoses. During trial, the Republic presented documentary evidence attesting to
the positions held, business interests, income, and pertinent transactions of the Gimenez
Spouses. The Republic several witnesses who testified on the bank accounts and businesses
owned or controlled by them. Thereafter, the Republic then manifested that it was “no longer
presenting further evidence.Respondents then filed a Motion to Dismiss on Demurrer to Evidence,
arguing that the Republic showed no right to relief as there was no evidence to support its cause
of action.
ISSUE: Was the Motion to Dismiss on the ground of Demurrer to Evidence correct or proper?
Held:
A liberal application of the Rules is in line with the state’s policy to recover ill-gotten wealth.
Although trial courts are enjoined to observe strict enforcement of the rules of evidence, in connection
with evidence which may appear to be of doubtful relevancy, incompetency, or admissibility, we have
held that.It is the safest policy to be liberal, not rejecting them on doubtful or technical grounds
12. Patula v. People, G.R. No. 164457, April 11, 2012
Facts:
Petitioner was charged with estafa before RTC Dumaguete City. Petitioner pled n o t g uilt y to the
offense charged in the information. At pre-trial, no stipulation of facts was had, and petitioner did
not avail herself of plea bargaining. Thereafter, trial on the merits ensued. After the Prosecution
rested its case, the Defense decided not to file a demurrer to evidence although it had manifested
the intention to do so, and instead rested its case. RTC rendered its decision finding petitioners
guilty of estafa.
ISSUE: Whether or not the ledgers and receipts were admissible as evidence of petitioner's guilt
for estafa as charged despite their not being duly authenticated.
Held:
A public document, by virtue of its official or sovereign character, or because it has been acknowledged
before a notary public (except a notarial will) or a competent public official with the formalities required by
law, or because it is a public record of a private writing authorized by law, is self-authenticating and
requires no further authentication in order to be presented as evidence in court. In contrast, a private
document is any other writing, deed, or instrument executed by a private person without the intervention
of a notary or other person legally authorized by which some disposition or agreement is proved or set
forth.
13.Chan v. Chan, G.R. No. 179786, July 24, 2013
Petitioner Chan filed a petition for the declaration of nullity of her marriage to respondent Johnny Chan,
claiming that he failed to care for and support his family and that he was diagnosed as mentally deficient.
During the pre-trial conference, Josielene pre-marked the Philhealth Claim Form that Johnny attached to
his answer as proof that he was fo rcibly confined at the rehabilitation unit of a hospital. . The request was
accompanied by a motion to "be allowed to submit in evidence" the records sought by subpoena duces
tecum. Johnny opposed the motion.
ISSUE: Whether the opposition by Johnny for the production of the evidence is proper
Held:
Objection to evidence offered orally must be made immediately after the offer is made. Objection to a
question propounded in the course of the oral examination of a witness shall be made as soon as the
grounds therefor shall become reasonably apparent. It is when those records are produced for
examination at the trial, that Johnny may opt to object, not just to their admission in evidence, but more so
to their disclosure.
14. People v. Kempis, G.R. No. 97169, May 10, 1993
Facts:
Teofilo Kempis then a member of the Philippine Constabulary was convicted by the Trial Court for
the crime of murder for the killing of Lolito Rivero. Teofilo submitted to the trial court as Exhibit
“1” a portion of page 5 of the Investigation Report made be Sgt. Rosales. .” As regards to said
evidence the Trial Court in its decision stated “ it is quite evident that the accused himself was the
informant” and that the Entry Number 904 referred in Exhibit “1” and also Entry Number 905 in the
Mayorga Police Blotter do not state when Lolito Rivera was killed.
ISSUE:
WON it was proper that the trial Court took into consideration portions of the Investigation Report which
were not included in Exhibit “1”, particularly the entries in Entry 904 and 905 of the Mayorga Police Blotter
Held:
Should a party submit part of a document, the court may not take into consideration the whole documents
nor other documents that were referred to in the portion of that submitted in evidence. The court may only
take into consideration the same should the party that submitted the same offer the whole in evidence, or
the other party move that the whole be received in evidence.
15. People v. Plasencia y Desamparado, G.R. No. 90198, November 7, 1995
Facts:
Tonying”, “Ruby”, and “Julito” were convicted by the RTC for the crime of Murder, for the killing of
Herminio Mansueto. On appeal the appellants attack the credibility of the lone witness Francisca Espina
“Pansing”. Tonying claims that the witness is prejudiced due to the fact that his dog has bitten her child in
the past. Julito assails the credibility of the witness due to her “jittery actuations” while testifying and
questions the findings of the ponente as he was not presiding at the time of the examination of such
witness.
ISSUE:WON the witness was allowed to read the notes written on her hand while testifying?
Held:
Yes The use of memory aids during an examination of a witness is not altogether proscribed. The
credibility of a witness is not tarnished by the fact that he/she uses notes while testifying, as long as there
is permission of the court as long and falls under R132 S16 of the rules of court. In other words, pwede
magkodigo basta ikaw gumawa.
