You are on page 1of 1

WIDOWS AND ORPHANS VS CA - Before secondary evidence may be admitted, there must be 1) proof of the execution of the

original writing and 2) that it has been lost or destroyed or cannot be produced in court or that it is in the possession of the
adverse party who has failed to produce it after reasonable notice (Michael and Co. v. Enriquez, 33 Phil. 87 [1915]; Republic v.
Court of Appeals, 73 SCRA 146 [1976]).