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EVIDENCE Case Doctrines

I. PRELIMINARY CONSIDERATION

People v Fetalino
525 SCRA 170

Evidence. The evidence which should be considered by the court in criminal cases
need not be limited to the statements made in open court, rather it should include all
documents, affidavits or sworn statements of the witnesses and other supporting
evidence. When a sworn statement has been formally offered as evidence, it forms an
integral part of the prosecution evidence which should not be ignored for it
complements and completes the testimony on the witness stand. A sworn statement is
a written declaration of facts to which the declarant has sworn before an officer
authorized to administer oaths. This oath vests credibility and trustworthiness on the
document. The fact that witness fails to reiterate, during trial, the contents of his sworn
statement should not affect his credibility and render the sworn statement useless and
insignificant, as long as it is presented as evidence in open court.

Ong Chia v Republic


328 SCRA 749

Naturalization. The rule on formal offer of evidence is clearly not applicable to a


petition for naturalization; decisions in naturalization proceedings are not covered by
the rule on res judicata. Rule 143 of the Rules of Court provides that These rules shall
not apply to land registration, cadastral and election cases, naturalization and
insolvency proceedings, and other cases not herein provided for, except by analogy
or in a suppletory character and whenever practicable and convenient.

The reason for the rule prohibiting the admission of evidence which has not been
formally offered is to afford the opposite party the chance to object to their
admissibility.
People v Valdez
341 SCRA 25

Presumption of innocence. The evidence arrayed against the accused must not only
stand the test of reason, it must likewise be credible and competent; Competent
evidence is generally admissible evidence, and admissible evidence, in turn, is
evidence of such a character that the court or judge is bound to receive it, that is,
allow it to be introduced at trial.

Where the evidence is insufficient to overcome the presumption of innocence in favor


of the accused, then his acquittal must follow in faithful obeisance to the fundamental
law.

Zulueta v CA
253 SCRA 699

Illegally obtained evidence. Privacy of communication and correspondence is


inviolable. The only exception in the Constitution is if there is a lawful order from a
court or when public safety or order requires, otherwise, as prescribed by law.

People v Yatar
428 SCRA 504
Circumstantial Evidence. An accused can be convicted even if no eyewitness is
available, so long as sufficient circumstancial evidence is presented toprove beyond
doubt that the accused commited the crime.

Espaol v Formoso
525 SCRA 216

Judicial Notice. Courts are not authorized to take judicial notice of contents of records
of other cases even when such cases have been tried or pending in the same court.

Metrobank v PBCOM
536 SCRA 556

Judicial Notice. While the Negotiable Instruments Law is silent with respect to crossed
checks, the Supreme Court nonetheless has taken judicial cognizance of the practice
that a check with two parallel lines on the upper left hand corner means that it could
only be deposited and not converted into cash.