3) Flores v. People G.R. No.

222861, 23 April 2018

a. Relevant facts involved:

Flores figured in a vehicular accident with a passenger jeepney. The parties were taken to the Police
Station where PO2 Flores investigated the accident. Afterwards, France was asked to remain and told to
return after two days and prepare P2,000 so he can retrieve his driver’s license. Because he was not able
to furnish the amount at the desired period, he was told to return the next day, and was issued by Flores a
Traffic Violation Receipt, which served as his temporary driver’s license. This caused France to become
suspicious, as it was only the MMDA or City Hall that issued said receipts.

France went to the headquarters of the Presidential Anti- Organized Crime Task Force (PAOCTF) in
Camp Crame to file a complaint against Flores. The PAOCTF team then went to the police station with
France. Upon entering, PO2 Flores called him to his table, opened his drawer and told France to drop the
money inside. As soon as France asked for his driver’s license, the PAOCTF team entered the scene and
arrested PO2 Flores. They confiscated things in his drawer, including the marked money. He was turned
over to Camp Crame for ultraviolet examination and execution of the Karagdagang Sinumpaang Salaysay
regarding the incident.

However, before the court, PO2 Flores contradicted the Salaysay, testifying that the marked money was
placed by France in his drawer while he was in the restroom when he refused the persistent demands of
France to receive the money.

b. Evidence offered by the proponent:

Photocopies of the following: (a) laboratory report finding traces of UV powder on his index finger; (b)
alleged marked money; (c) Traffic Violation Receipt; and the (d) Karagdagang Sinumpaang Salaysay
c. Ground/s relied upon by the adverse party in objecting to the admissibility of item (b):

That the evidence violated the Best Evidence Rule and the marked money was never presented in court.

d. Relevant issues involved:

(1) WON the presentation of the photocopy of the marked money instead of the original pieces violated
the BER;
(2) Failure to authenticate the laboratory report by testimony of the forensic chemist;
(3) Inconsistency in the Salaysay and the testimony in open court

e. Ruling of the SC on the in/admissibility of the evidence:

Non-presentation is not fatal to the cause of the prosecution. The BER applies only when the contents of
the document are the subject of the inquiry. When the issue is only as to WON such document was
actually executed or exists, BER does not apply. The marked money was presented for the sole purpose
of establishing its existence, not its contents. Thus, no need to account for the original.
Presence of the UV fluorescent powder is not an indispensable evidence to prove receipt of the marked
money. The laboratory report is a mere corroborative evidence which is not material enough to alter the
judgment.
The discrepancy will not instantly result in an acquittal. The testimony in open court prevails. Affidavits are
usually abbreviated and inaccurate, generally considered inferior to court testimonies. It is often
incomplete, resulting in contradiction. Further, the court found France’s testimony to be candid,
straightforward and categorical. SC gave credence to the discretion of the trial court to observe the
demeanor of witnesses during trial.
f. Effect/s of the 2019 Proposed Amendments to the Rules on Evidence on item (f):
The original of a document covers the document itself or any counterpart intended to have the same
effect by a person executing or issuing it. A duplicate, produced from the same matrix or impression as
the original, now serves as a functional equivalent of the original as long as it is an accurate reproduction
thereof under Sec 4b of Rule 130, thus making photocopies admissible under the BER.