In fact, the contents of the certifications are hearsay because respondent's sole witness and

attorney-in-fact, Lea Galeno Barraca, was incompetent to testify on the veracity of their
contents, 31 as she did not prepare any of the certifications nor was she a public officer of the
concerned government agencies.

should be borne in mind that "hearsay evidence, whether objected to or not, has no
probative value unless the proponent can show that the evidence falls within the exceptions to the
hearsay evidence rule,"33 which do not, however, obtain in this case. Verily, while respondent's
documentary evidence may have been admitted due to the opposing party's lack of objection, it does
not, however, mean that they should be accorded any probative weight.

Nevertheless, the issues of Mr. Villafuerte's incompetence as a witness to testify on the

object and documentary evidence presented and the propriety of presentation of the Questioned
Documents, while intimately related, are separate and distinct from each other.
Moreover, to disallow the presentation of the Questioned Documents on the ground of Mr.
Villafuerte's incompetence to identify and authenticate the same for lack of personal knowledge is
premature at this juncture. Sec. 34, Rule 132 of the Revised Rules on Evidence clearly instructs that:

Section 34. Offer of evidence. -The court shall consider no evidence which has not been
formally offered. The purpose for which the evidence is offered must be specified.

Sec. 2027 of the same Rule, in turn, provides that before any private document is received in
evidence, its due execution and authenticity must be proved either by anyone who saw the
document executed or written, or by evidence of the genuineness of the signature or handwriting of
the maker. Following Sec. 1928 must of Rule 132, the documents sought to be presented undoubtedly
are private in character, and hence, be identified and authenticated in the manner provided in the
Rules. The failure to properly authenticate the documents would result in their inadmissibility.29 The
court, however, can only rule on such issue upon the proponent's formal offer of evidence, which,
pursuant to Sec. 35,30 Rule 132, is made after the presentation of the party's testimonial evidence.

. The Identification of the document before it is marked as an exhibit does not constitute the
formal offer of the document as evidence for the party presenting it. Objection to the Identification
and marking of the document is not equivalent to objection to the document when it is formally
offered in evidence. What really matters is the objection to the document at the time it is formally
offered as an exhibit.

private documents are those that do not fall under any of the enumerations in Section 19,
Rule 132 of the Rules of Court.8 Section 209 of the same law, in turn, provides that before any private
document is received in evidence, its due execution and authenticity must be proved either by
anyone who saw the document executed or written, or by evidence of the genuineness of the
signature or handwriting of the maker. Here, respondent's documentary exhibits are private
documents. They are not among those enumerated in Section 19, thus, their due execution and
authenticity need to be proved before they can be admitted in evidence. With the exception
concerning the summary of the weight of the steel billets imported, respondent presented no
supporting evidence concerning their authenticity.10 Consequently, they cannot be utilized to prove
less of the insured cargo and/or the short delivery of the imported steel billets. In sum, we find no
sufficient competent evidence to prove petitioner's liability.

Aside from their being not properly identified by any competent witness, the loss of the
principals thereof was not established by any competent proof.