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Public documents are admissible in

court without further proof of their


due execution and authenticity

A public document is defined in Section 19, Rule 132 of the Rules of Court as follows:

SEC. 19. Classes of Documents. For the purpose of their presentation in evidence,
documents are either public or private.

Public documents are:

(a) The written official acts, or records of the official acts of the sovereign authority,
official bodies and tribunals, and public officers, whether of the Philippines, or of a
foreign country;

(b) Documents acknowledged before a notary public except last wills and testaments;
and

(c) Public records, kept in the Philippines, or private documents required by law to be
entered therein.

All other writings are private. [emphasis and underscore ours]

The Firearm Identification report showing that a .45 caliber slugs recovered from the
crime scene were fired from the .45 caliber pistol with serial number 22222 which
firearms license under the name of A is a public document. As a public document, the
rule on authentication does not apply. It is admissible in evidence without further proof
of its due execution and genuineness; the person who made the report need not be
presented in court to identify, describe and testify how the report was conducted.
Moreover, 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 stated therein. 20

In the present case, notwithstanding the fact that it was Dr. Jasmine M. Garibay
the Chief of Crime Laboratory Regional Office 5 who was presented in court to identify
the Firearm Identification Report and not SPO1 Digong R. Bato the Firearm Examiner
who actually conducted the Firearm Identification, the report may still be admitted
because the requirement for authentication does not apply to public documents. In other
words, the Firearm examiner does not need to be presented as witness to identify and
authenticate the Firearm Identification report. Furthermore, the entries in the Firearm
Identification Report are prima facie evidence of the facts they state, that is, the .45
caliber pistol with serial number 22222 is owned by A. Accordingly, we hold that the
Firearm Identification Report is admissible as evidence.