CASE DIGEST IN EVIDENCE

ATTY. TET OCAMPO

GEORGE B. HIPOLITO JR.
BSC4-Y1-2
TABLE OF CONTENTS
WEEK 2: BASIC PRINCIPLES OF EVIDENCE
STONEHILL V. DIOKNO G.R. No. L-19550 June 19, 1967
WEEK 3: ADMISSIBILITY
PLANTERAS, JR. V. PEOPLE, G.R. NO. 238889, OCTOBER 03, 2018
PEOPLE V BERNAL, G.R. NO. 113685, JUNE 19, 1997
PP V. RICARDO BOSI y DANAO (G. R. NO. 193665, JUNE 25, 2012)
Revilla v. Court of Appeals 217 SCRA 583, 1993

WEEK 4: JUDICIAL NOTICE

PEOPLE V TUNDAG, G.R. Nos. 135695-96, OCTOBER 12, 2000
EXPERTRAVEL & TOURS INC. VS CA (GR NO. 152392 MAY 26, 2005)
STATE PROSECUTORS V. MURO, A.M. NO. RTJ-92-876, SEPTEMBER 19,
1994
ATCI Overseas Corporation v. Echin, G.R. No. 178551, October 11, 2010
Republic v. Sandiganbayan, G.R. No. 152375, December 16, 2011
Social Justice Society v. Atienza, G.R. No. 156052 (March 07, 2007)

WEEK 5: OBJECT EVIDENCE

PEOPLE V. RAMIREZ, G.R. No. 225690, JANUARY 17,2018
WEEK 7-8: DOCUMENTARY EVIDENCE (PART 1 & 2)
EDSA SHANGRI LA HOTEL AND RESORT, INC V. BF CORPORATION, G.R. No.
145842, JUNE 27, 2008
E. MICHAEL & Co. INC., V. ENRIQUEZ, G.R. No. L-10824, DECEMBER 24,
1915)
WEEK 9: TESTIMONIAL EVIDENCE
EAGLERIDGE DEVELOPMENT CORP. V. CAMERON GRANVILLE 3 ASSET
MANAGEMENT, INC., G.R. No. 204700, NOVEMBER 24, 2014
AIR PHILIPPINES CORP. V. PENNSWELL, INC., G.R. No. 172835, DECEMBER
13,2007
PEOPLE V. OCHOA, G.R. No. 172792
DST MOVERS CORP. V. PEOPLE’S GENERAL INSURANCE CORP., G.R. No.
198627
WEEK 10: ADMISSION VS CONFESSION
ESTRADA V. DESIERTO, G.R. No. 146738, APRIL 3,2001
People v. Cachuela, G.R. No. 191752, June 10, 2013

STONEHILL V. DIOKNO G.R. No. L-19550 June 19, 1967

FACT:
Forty-two search warrants were issued by different judges, directing police
to search the homes of Harry Stonehill, Karl Beck, Robert Brooks, and other
people. The warrants permitted the seizure of a variety of business-related
objects, including financial records, letters, and papers, about claims of
breaking the Revised Penal Code, the Internal Revenue Code, Tariff and
Customs Laws, and Central Bank Laws. Stonehill and his other petitioners
challenged the search warrants and the ensuing property seizures, claiming
that the warrants violated the Constitution's prohibitions on arbitrary
searches and seizures since they looked like general warrants. The
respondents countered that the search warrants in question were legitimate
and issued in compliance with the law. They added that any flaws in the law
were fixed Regardless of the legality of the searches and seizures, the
petitioners' agreement and the confiscated properties should be accepted as
evidence. On March 22, 1962, the petitioner's motion for a writ of
preliminary injunction was granted by the Supreme Court. On June 29,
1962, however, the Court dissolved or partially released the injunction about
the papers, records, and other objects that had been taken from the
corporate premises where the petitioners were employed. However, the
injunction continued to apply to any papers, documents, and objects that
were discovered and taken from the petitioners' homes.

ISSUE:
Whether or not the contention is that the search warrants violate the
constitutional prohibition against unreasonable searches and seizures, and
consequently, the properties seized are argued to be inadmissible as
evidence against Stonehill and his co-petitioners.

RULING/DECISION:
The court ruled that the petitioners lack grounds to challenge the legality of
the warrants and the seizures made under them. This decision was based on
the concept that these corporations have distinct identities separate from
the individuals petitioning, regardless of their shareholding or roles within
these companies. The seriousness of the irregularities in connection with the
disputed search warrants led the court to modify Rule -22 of the former
Court Rules, specifying that a search warrant should only be issued based on
probable cause related to a specific offense. Unsatisfied with this condition,
the court further directed that a warrant shouldn't cover more than one
specific offense.
The court found a grave violation of the Constitution in the application for
the contested search warrants. The description of the items to be searched
for and seized was overly broad, encompassing various records and
documents related to all business transactions, regardless of legality. This
authorization directly conflicted with the explicit instruction in our Bill of
Rights, which demands a specific description of items to be seized.
Additionally, it undermined the primary objective of limiting searches to
prevent the issuance of general warrants.

PLANTERAS, JR. V. PEOPLE, G.R. NO. 238889, OCTOBER 03, 2018

FACT:
P/S Int. After receiving reports sometime in the second week of March 2009
about the alleged trafficking in persons and sexual exploitation being
committed at the said place, Audie Villacin directed the elements of the
Regional Investigation Detective Division (RIDM) to conduct surveillance
operations at x Lodge, owned by the petitioner and his wife, Christina
Planteras, located along x, Cebu City. On March 19, 2009, PO3 Jose Erwin
Dumaguit (PO3 Dumaguit) and PO1 Arnold Rusiana (PO1 Rusiana)
conducted another surveillance at the said location. Following this, on April
28, 2009, the Department of Social Welfare and Development (DSWD)
representatives, the Carbon Police Station, barangay tanods, and members
of the Regional Special Investigation Unit conducted an entrapment
operation. Marichu Tawi approached PO3 Dumaguit and PO1 Llanes at the x
Lodge, offering girls sexual favors for P300.00 each. PO3 Dumaguit and PO1
Llanes selected three (3) girls, one of whom was A, and then gave Buhisan
the marked money, totaling P900.00. Additionally, the police officers paid
Tawi a P200.00 "tip". The remainder of the crew was then subjected to a
"missed call" as PO3 Dumaguit carried out the prearranged signal. PO3
Dumaguitan declared that they were police officials as soon as the other
members of the team arrived at the X Lodge. Immediately after, arrested
were the petitioner, Buhisan Tawi, and his spouse, Christina.

ISSUE:
Whether or not the petitioner broke Section 5, par. (a) of Republic Act (R.A.)
No. 9208 or encouraging human trafficking.

RULING/DECISION:
Yes. R.A. Section 5(a). No. 9208, which says this under Section 5. actions
that encourage human trafficking. - It is illegal to engage in any of the
following activities that encourage or assist human trafficking: (a) To
intentionally lease or sublease, use, or permit to be used any house,
building, or establishment to promote human trafficking. xx By the
aforementioned legal provisions, an accused person must, to be found guilty
of the crime of promoting human trafficking, (a) knowingly lease or
sublease, or permit to be used, any house, building, or establishment; and
(b) such use of the house, building, or establishment is to promote human
trafficking. Unquestionably, the petitioner is the lodge's owner and manager.
Additionally, evidence was provided to show that the pimps, clients, and
prostitutes who congregate close to the location in question use it for their
illicit activities. In this case, the entirety of the circumstantial evidence
presented by the prosecution proves beyond a reasonable doubt that the
petitioner permitted the use of his establishment in the promotion of human
trafficking. The prosecution also properly established the petitioner's
knowledge about the activities taking place inside his establishment, most
notably through the testimony of AA. Regarding the petitioner's assertion
that since AA freely engaged in prostitution, no in-person trafficking was
done, this assertion is meritless. Under Republic Act No. 9208.45, knowledge
or consent of the minor is not a defense. The victim's consent is meaningless
because human traffickers use coercive, abusive, or deceptive methods to
obtain it. A minor's consent is not given voluntarily, even in the absence of
coercive, abusive, or deceptive tactics. Consequently, petitioner Antonio
Planteras, Jr.'s May 18, 2018, Petition for Review on Certiorari under Rule 45
of the Rules of Court is denied for lack of merit, and petitioner is ordered to
pay P50,000.00 in exemplary damages and P100,000.00 in moral damages
to AA.
 PEOPLE V BERNAL, G.R. NO. 113685, JUNE 19, 1997

FACT:
The case revolves around Theodore Bernal and two unidentified individuals
accused of kidnapping Bienvenido Openda, Jr. Bernal, pleading not guilty,
stood trial where the prosecution presented four witnesses. During his
defense, Bernal testified that while passing by, he joined Roberto Racasa
and Openda, Jr. in a drinking session. Soon after, he left to attend to his
child. Shortly thereafter, two men approached Openda, Jr., one brandishing
a handgun, claiming to be policemen and citing an issue ("atraso") with him,
swiftly abducting him. Racasa then informed Openda, Jr.'s mother, of the
incident. The prosecution's theory, based on Salito Enriquez's testimony,
implies Openda, Jr.'s kidnapping was motivated by his alleged affair with
Bernal's wife, Naty, who remains missing. However, the defense contends
that Openda, Jr. was a previously arrested drug-pusher and wasn't
kidnapped. The trial court found Bernal guilty based significantly on Racasa's
testimony, where he recounted the events leading to Openda, Jr.'s
disappearance. Enriquez, a friend of Openda, Jr., testified that Openda, Jr.
admitted to an affair with Naty, even receiving money from her for a motel.
This revelation suggested Naty's infidelity as a potential motive for Bernal's
desire for retaliation.

ISSUE:
Whether or not the witness's testimony regarding a declaration made by a
deceased person that goes against their wishes may be admitted into
evidence against a third party.

RULING/DECISION:
According to Section 38, Rule 130 of the Revised Rules on Evidence,
Openda, Jr.'s confession to Enriquez about his extramarital affair with
Bernal's wife is admissible in evidence. This means that a declaration made
against the declarant's interest by a deceased or unable to testify against
the declarant's interest if the fact asserted in the declaration was at the time
of its making so far contrary to the declarant's interest that a reasonable
man in his position would not have made the declaration unless he believed
it to be true, may be admitted in evidence against the declarant, his
successors in interest, and third parties. *The confession that Openda, Jr.
made to Enriquez regarding his extramarital affair with Bernal's wife is
admissible in evidence under Section 38, Rule 130 of the Revised Rules on
Evidence. Thus, a declaration made against the declarant's interest by a
deceased or unable to testify against the declarant's interest may be
admitted in evidence against the declarant, his successors in interest, and
third parties if the fact asserted in the declaration was at the time of its
making so strongly contrary to the declarant's interest that a reasonable
man in his position would not have made the declaration unless he believed
it to be true.

PP V. RICARDO BOSI y DANAO (G. R. NO. 193665, JUNE 25, 2012)

FACT:
The victim, identified as AA, stated in her testimony that on November 2,
2001, she was asleep when her mother and father woke her up, telling her
to move to the sald, where her siblings and parents were also sleeping.
Fearful, AA followed her father's instructions. After that, she went back to
sleep, but she woke up when she felt her father removing her underwear.
While the accused-appellant was holding her hand, AAA attempted to push
and kick him; in the end, the accused-appellant climbed on top of her,
kissed her, and inserted his penis inside her vagina. Fearing that her father
would harm her mother and siblings, AAA gave in to his ferocious urge. The
accused-appellant then made another unsuccessful attempt to rape AAA at
around five in the morning. The next morning, AAA, and her aunt Raquel
Bosi—the accused-appellant's sister—reported the crime to the Department
of Social Welfare and Development (DSWD). The accused-appellant faced
rape charges. In his defense, the accused appellant merely refuted the
charge made against him. He said that because he slapped her after she
eloped with her boyfriend and because he asked her to put her studies on
hold for a year, AAA accused him of rape. According to him, his daughter
even forewarned him that he would get his revenge. The accused appellant
was declared guilty by the RTC. It supported AAA's testimony, which was
characterized by her convulsive sobbing and a clear, convincing, and
consistent account of her ordeal. The CA upheld the decision of the RTC.

ISSUE: Whether or not the private complainant's version was improbable,

and the trial court made a grave mistake by accepting it because of her
animosity toward the accused-appellant.

RULING/DECISION:
The accused-appellant argues that despite her animosity toward him and the
version being implausible, the trial court committed a grave error by
accepting it. According to the accused-appellant, AAA accused her father of
rape because she disapproved of his despotic behavior. But we agree with
the RTC and the CA when they state that a daughter needs more than just
disciplinary action to accuse her father and fabricate charges of rape. If the
victim's father was not the real perpetrator, this would embarrass and
humiliate her as well as her family. We believe that it is impossible to simply
disregard AAA's continuous and unwavering testimony that implicates her
father in the rape.

Revilla v. Court of Appeals 217 SCRA 583, 1993

FACT:
The single Don Cayetano Revilla possessed six land parcels in his hometown
of Bulacan and two land lots in Manila with buildings on them. The value of
these properties is P30M. He left all his possessions, including the petitioner
Heracio Revilla, to his nine nephews and nieces in a 13-page last will that he
signed in 1978. He left 1/10 of his estate to each, keeping the remaining 10
percent for the care of religious images he kept in a chapel in Bulacan and
for masses to be said after his death. Don Cayetano applied for probate of
his will during his lifetime, and the CFI Manila granted it. Nevertheless, the
records were destroyed in the fire that destroyed Manila City Hall.
Reconstitution of the records was requested in writing, and it was approved.
Following Don Cayetano's passing, Heracio Revilla submitted a second will
petition, establishing Heracio as executor and only heir of his uncle's estate
or the purportedly executed will from 1982. The process of probate was
opposed by Heracio's eight siblings due to the following reasons: -Cayetano
never disclosed that he had revoked the 1978 will until after he died in 1978.
- The 1982 will was not carried out legally, and Cayetano's signature differed
from what was typical for him to sign. When Cayetano carried out the will,
he was not of sound mind. - That excessive pressure and influence were
used to carry out the purported will - The 1978 will is null and void because
it was executed under duress or the influence of threats or fear. - Cayetano
made a mistake, the signatures in the purported will were obtained through
fraud, and when he signed the document, he had no intention of it being his
will. The second will be rejected by the trial court. The trial court was upheld
by the CA after an appeal.

ISSUE:
Whether or not It was incorrect for the court to reject the second will.

RULING/DECISION:
Don Cayetano did not know about the second will he was supposed to have
made when he testified during the reconstitution proceedings. Declaring it to
be his only will, he identified his first will. He was unable to execute a second
will because he was unable to sign any documents while confined to the
hospital due to his illness, which kept him there for two months. The will was
produced during the reconstitution process. It was put inside a browned
envelope with the words "Buksan ito alkalizing ko," Cayetano acknowledged.
to become open. He acknowledged having signed the original will and
recognized it. Cayetano stated in the court documents that he did not create
a second last will following the original one's probate.

PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. TOMAS

TUNDAG, Accused-Appellant G.R. Nos. 135695-96, October 12, 2000

FACTS:
On November 18. Mary Ann Tundag, a private complainant, submitted two
distinct complaints for incestuous rape to the Mandave City Prosecutor's
Office in 1997. All that the appellant could do was deny. He asserted that
the private complainant had made up the rape allegations against him
because he had a fight with his daughter after he chastised her for leaving
the house whenever he wasn't there. The appellant did not provide a witness
to support his claims. The trial court found that the accused Thomas
Rundaga was guilty of rape beyond a reasonable doubt on August 31, 1998,
and he was given the death penalty. The prosecution's evidence, as
presented in the merits trial, makes it abundantly evident that the private
complainant Living at Galaxy Compound in Mandaue City with her father, the
accused, is 13-year-old Mary Ann Tundag, who lacks reading and writing
skills and has an IQ of 76%, indicating a very low general mental ability. The
trial court did not find the appellant credible when it found him guilty of rape
twice, despite his argument that the complainant's accusations were false.
Thus, the request.

ISSUE:
Whether or not the defense attorney's admission regarding the victim's age
entitles the trial court to judicial notice.

RULING/DECISION:
In a case involving horrible crimes and the death penalty, the court
dismissed the appellant's feeble alibi and denial defense and upheld the
conviction. The medical evidence and the victim's comprehensive and
consistent testimony reinforced the guilty decision. The court did draw
attention to the inadequate evidence of the victim's age and the
inappropriate admission of judicial notice in the absence of a hearing. The
court addressed the optional and required elements of judicial notice and
underlined the need for independent verification of the victim's age. The
court imposed the death penalty for the first rape under R.A. despite the
ambiguity surrounding the victim's age. 7659 and upheld the punishment
under R.A. for the second rape. 8353. In the end, the petition was turned
down.

EXPERTRAVEL & TOURS INC. VS CA (GR NO. 152392 MAY 26, 2005)

FACTS:
Korean Airlines (KAL), a corporation registered in South Korea and
authorized to operate in the Philippines, engaged Atty. Mario Aguinaldo and
his law firm as its counsel. Acting through Atty. Aguinaldo, KAL filed a
monetary collection Complaint against ETI in the Manila Regional Trial Court
(RTC). Atty. Aguinaldo signed the verification and certification against forum
shopping, claiming to be the resident agent and legal counsel of KAL,
responsible for preparing the complaint. ETI moved to dismiss, arguing that
Atty. Aguinaldo lacked the authority to execute the verification and
certificate, as mandated by Section 5, Rule 7 of the Rules of Court.
Subsequently, KAL, through its general manager Suk Kyoo Kim, submitted
an Affidavit asserting that a special teleconference of the board of directors
took place, attended by Kim and Atty. Aguinaldo. The affidavit stated that
during this teleconference, the board approved a resolution authorizing Atty.
Aguinaldo to execute the certificate of non-forum shopping and file the
complaint. However, Kim admitted that there was no written copy of the
resolution. The trial court denied ETI's motion to dismiss, relying on the
claims of Atty. Aguinaldo and Suk Kyoo Kim regarding the teleconference.
ETI sought reconsideration, contending that the court should not have taken
judicial notice of the teleconference without a prior hearing. The trial court,
in its August 8, 2000, Order, rejected this argument. ETI then filed a petition
for certiorari and mandamus challenging the RTC orders. The Court of
Appeals dismissed the petition, stating that Atty. Aguinaldo was duly
authorized by the board resolution and was KAL's resident agent. The CA
affirmed the RTC's decision to take judicial notice of the teleconference.
ETI's motion for reconsideration was denied by the CA.

ISSUE:
Whether or not the courts can use the teleconference as legal.

RULING/DECISION:
Certainly, in the modern age of technology, the courts can recognize that
business transactions are conducted through teleconferencing.
Teleconferencing involves interactive group communication using electronic
means, allowing people in different locations to connect. This method, which
includes video conferencing, computer conferencing, and audio conferencing,
serves as an alternative to face-to-face meetings. The use of
teleconferencing, including among private corporations' board members, is a
reality supported by Republic Act No. 8792. SEC Memorandum Circular No.
15, issued by the Securities and Exchange Commission, provides guidelines
for such conferences. The court agrees with the Regional Trial Court's view
that individuals in the Philippines can engage in teleconferencing with
counterparts in South Korea for business transactions or corporate
governance matters.

STATE PROSECUTORS V. MURO, A.M. NO. RTJ-92-876, SEPTEMBER

19, 1994

FACTS:
Judge Manuel T. Muro of the Regional Trial Court (RTC) of Manila, Branch 54,
faced charges of ignorance of the law, grave misconduct, and violations of
the Code of Judicial Conduct from State Prosecutors Nilo C. Mariano, George
C. Dee, and Paterno V. Tac-an. The charges stemmed from the dismissal of
11 cases against Imelda Marcos for violating the Central Bank Foreign
Exchange Restriction in Circular 960. The judge dismissed all cases solely
based on reports from two reputed national newspapers, which he deemed
as evidence that the President had lifted all foreign exchange restrictions.
The judge believed that this reported announcement effectively repealed
Circular 960, leading him to dismiss the cases motu proprio. Petitioners
argued that this was not a simple misapplication of the law but a denial of
due process, as the judge dismissed the cases without a motion to quash
and without allowing the prosecution to be heard. They contended that this
action demonstrated bad faith and partiality. Additionally, petitioners alleged
that the judge exercised grave abuse of discretion by taking judicial notice of
the President's published statement in the newspapers, a matter not
officially in force as law at that time.
ISSUE:
Whether or not the judge in question is accused of committing serious
misconduct by improperly exercising judicial notice of the President's
statement, as reported in newspapers, announcing the lifting of foreign
exchange restrictions. This alleged abuse of discretion served as the basis
for dismissing the case.

RULING/DECISION:
Yes, the judge committed a serious error by taking judicial notice of a law
that was not yet in force. The law, Circular 1353, was not a matter of
common knowledge at the time and did not meet the requisites for judicial
notice. The judge admitted to not having seen the official text of Circular
1353 when he prematurely took judicial notice based on his knowledge,
which does not align with the public knowledge required for such notice. To
take judicial notice, three conditions must be met: the matter must be of
common and general knowledge, well-settled, and within the court's
jurisdiction. The judge's action in dismissing the cases without allowing the
prosecution an opportunity to be heard is not a mere misapplication of the
law but a clear denial of due process, indicative of bad faith and partiality.
Despite the expectation of a judge's competence and qualifications, the
judge's arguments and logic lack cogency. The Supreme Court, citing
precedents where judges were dismissed for incompetence, finds Judge
Manuel T. Muro guilty of gross ignorance of the law. As a result, he is
dismissed from service, which includes the cancellation of eligibility,
forfeiture of leave credits and retirement benefits, and disqualification from
reemployment in the government service.

ATCI Overseas Corporation v. Echin, G.R. No. 178551, October 11,

2010

Facts:

Josefina Echin was recruited by ATCI Overseas Corporation on behalf of

Kuwait's Ministry of Public Health for a medical technologist position under a
two-year contract. The contract specified a one-year probationary period for
newly hired employees. Echin was deployed on February 17, 2000, but her
employment was terminated on February 11, 2001, allegedly for not passing
the probationary period. She filed an illegal dismissal complaint against
ATCI, the local recruitment agency represented by Amalia Ikdal, and the
Ministry. The Labor Arbiter ruled in favor of Echin, ordering the petitioners to
pay her US$3,600.00, equivalent to the unexpired three-month portion of
her contract. The NLRC upheld the Labor Arbiter's decision. The petitioners
appealed to the Court of Appeals, arguing that the Ministry, being a foreign
government agency, enjoys immunity from suits, extending such immunity
to them. Additionally, they claimed Echin's valid dismissal due to her failure
to meet performance standards within Kuwait's Civil Service Laws' one-year
requirement. The Court of Appeals affirmed the NLRC Resolution,
maintaining the decision in favor of Echin.
ISSUE:
Whether or not the petitioner is held accountable for wrongfully terminating
the respondent's employment.

RULING/DECISION:
The private recruitment agency, ATCI, cannot escape liability for the
financial claims of OFWs they deploy abroad by using the excuse that their
foreign principal enjoys immunity from lawsuits. Holding both parties jointly
and solidarity accountable aligns with the government's aim to safeguard the
rights of the workforce. Allowing ATCI to rely on their foreign principal's
immunity or delaying liability determination renders the joint and solidary
liability law ineffective. Regarding the argument that the terms of
employment were governed by Kuwaiti laws, it lacked proper substantiation.
In legal matters involving foreign laws, the burden of proof lies with the
party invoking them. In this case, ATCI failed to fulfill this burden, as the
documents provided didn't sufficiently prove the validity of the respondent's
termination under Kuwaiti laws. Additionally, according to R.A. 8042, Amalia
Ikdal, as a corporate officer, is equally liable. The law explicitly states that
the liability of the principal and the recruitment agency is joint and several,
extending to corporate officers and directors, making them jointly and
solidarity responsible for claims and damages in overseas employment
contracts.

Republic v. Sandiganbayan, G.R. No. 152375, December 16, 2011

FACTS:
In 1993, the Sandiganbayan (SB) consolidated cases related to recovering
the ill-gotten wealth of the Marcos Family. During the trial of Civil Case No.
0009, the petitioner sought to adopt testimonies and exhibits from another
case but was denied due to certain deponents' unavailability for cross-
examination. The petitioner's subsequent motions to have the SB take
judicial notice of the facts from the other case were repeatedly denied. The
petitioner claimed grave abuse of discretion, arguing that evidence from the
related case should be considered in the "parent" case.

ISSUE:
Whether or not courts in handling consolidated cases, have the authority to
recognize or acknowledge the testimony and evidence introduced in one of
the consolidated cases through the mechanism of judicial notice.

RULING/DECISION:
In the process of adjudicating a case during trial, courts are generally not
permitted to automatically take judicial notice of the contents of records
from other cases, even if those cases are tried or pending in the same court
and before the same judge. However, there are exceptions to this rule.
Courts may, for the convenience of all parties, consider all or part of the
original record of a case filed in its archives as read into the record of a
currently pending case, provided there is no objection from the adverse
party. Additionally, if the original record of a previous case is withdrawn
from the archives with the court's direction and the consent of the parties, it
can be admitted as part of the current case's record. Courts are also
mandated to take judicial notice of records from another case if sufficient
grounds within the current case's records warrant its dismissal. However, it
is crucial to avoid indiscriminately admitting evidence from one case into
another solely based on their presumed relationship, as this could lead to
judicial confusion. The petitioner's argument, suggesting that evidence from
related cases should be admitted without proper scrutiny, poses a risk of
creating confusion in the judicial process.

Social Justice Society v. Atienza, G.R. No. 156052 (March 07, 2007)

FACTS:
Ordinance No. 8027, enacted by the Sangguniang Panglungsod of Manila,
reclassified an area from industrial to commercial use, instructing businesses
disallowed in the region to cease operations within six months of the
ordinance's effectivity. This included the "Pandacan Terminals" of oil
companies Caltex (Philippines), Inc., Petron Corporation, and Pilipinas Shell
Petroleum Corporation. However, an understanding was reached between
the City of Manila, the Department of Energy (DOE), and the oil companies
through a memorandum of understanding (MOU). The MOU identified the
scaling down of the Pandacan Terminals as the most viable option. It
mandated the removal of 28 tanks, starting with the LPG spheres, and the
initiation of efforts to establish safety buffer and green zones around the
Pandacan Terminals. In return, the City Mayor and the DOE agreed to allow
the oil companies to continue operations within the limited area resulting
from joint efforts and the scale-down program. This MOU was subsequently
ratified by the Sangguniang Panlungsod in Resolution No. 97. Petitioners
seek a mandamus against Mayor Atienza, urging enforcement of Ordinance
No. 8027 and the immediate removal of the oil companies' terminals.

ISSUE:
Whether or not the respondent is obligated by law to carry out the
mandatory duty of enforcing Ordinance No. 8027 and issuing the directive
for the removal of the Pandacan Terminals.

RULING/DECISION:
Certainly, the mayor is mandated by the Local Government Code to fulfill the
compulsory legal obligation of enforcing Ordinance No. 8027. This
responsibility stems from the code's provision requiring the city mayor to
"enforce all laws and ordinances relative to the governance of the city,"
including Ordinance No. 8027. As the city's chief executive, the mayor is
duty-bound to uphold Ordinance No. 8027 unless repealed by the
Sanggunian or annulled by the courts. This duty is not discretionary but
rather a ministerial obligation. In the case of Dimaporo v. Mitra, Jr., it is
emphasized that officers cannot decline to perform their duty based on the
alleged invalidity of the statute imposing such duty. Allowing officers to
question the constitutionality of statutes and ordinances that assign duties to
them, without a prior judicial declaration of unconstitutionality, could
significantly impede the efficient conduct of public business.

PEOPLE V. RAMIREZ, G.R. No. 225690, JANUARY 17,2018

FACTS:
NORJANA SOOD was charged with selling shabu in 2009. The prosecution
claimed she was caught in a police operation, but she denied involvement,
stating she was a sidewalk vendor when apprehended by unknown
individuals. Despite procedural issues, including failure to conduct an on-site
inventory, the court convicted her based on the prosecution's account and
upheld this decision on appeal, citing minor procedural lapses that didn't
impact the case's integrity.

ISSUE:
Whether or not the main question revolves around whether there was
enough evidence to firmly establish the accused's guilt, beyond a reasonable
doubt, for the violation of Section 5, Article II of RA 9165.

RULING/DECISION:
In this legal case involving a drug-related offense, the accused was
convicted based on their alleged involvement in a buy-bust operation.
However, the court found multiple issues with the handling of evidence,
particularly about the mandated procedure outlined in Section 21 of RA
9165. There were discrepancies in testimonies regarding where the
inventory of seized drugs occurred, and essential witnesses were missing
during this process, raising doubts about the integrity of the evidence.
Additionally, the prosecution failed to justify deviations from the required
protocol, leading to questions about the authenticity of the seized drugs as
evidence. Ultimately, due to significant concerns about procedural
compliance and the integrity of the evidence, the court granted the
accused's appeal, acquitted them, and ordered their immediate release,
unless held for other lawful reasons. The Bureau of Corrections was
instructed to implement this decision promptly and report it back to the
court.

EDSA SHANGRI LA HOTEL AND RESORT, INC V. BF CORPORATION,

G.R. No. 145842, JUNE 27, 2008

FACTS:
These consolidated petitions (G.R. No. 145842 and G.R. No. 145873) under
Rule 45 seek to nullify the decisions of the Court of Appeals (CA). The
dispute arises from a construction contract between Edsa Shangri-la Hotel
and Resort, Inc. (ESHRI) and others against BF Corporation (BF) for the
EDSA Shangri-la Hotel. The contract outlined payment based on monthly
progress billings, and a legal battle ensued when ESHRI did not remit
payment for specific billings. BF filed a lawsuit for a sum of money and
damages. ESHRI counterclaimed, alleging overpayment, and seeking a
refund. The Regional Trial Court (RTC) ruled in favor of BF. During the
appeal process, ESHRI's bank account was garnished, leading to petitions
before the CA. The CA affirmed the RTC decision, stating that the issues
raised were factual and evidentiary and that BF had sufficiently proven its
case. These petitions aim to overturn the CA decisions.

ISSUE:
Whether or not the Court of Appeals made a mistake in its factual findings
by incorrectly applying the rules of evidence to the case.

RULING/DECISION:
The Supreme Court held that the Court of Appeals did not make a mistake
in its factual findings, emphasizing that, in an appeal by petition for review
on certiorari under Rule 45, only questions of law may be presented unless
there are compelling reasons. The Court outlined specific circumstances
where exceptions might apply, such as when the conclusion is based on
speculations, or the judgment is rooted in a misapprehension of facts. None
of these exceptions were found in the case. Regarding the admissibility of
photocopies of Progress Billing Nos. 14 to 19, PMIs, and WVOs, the Supreme
Court clarified that the best evidence rule, as defined in Rule 130, Section 3
of the Rules of Court, requires the production of the original writing.
However, secondary evidence is admissible when the original is lost,
destroyed, or under the control of the adverse party, provided certain
conditions are met. In this case, the circumstances fell under the exception
outlined in Rule 130, Section 3. As a result, the Supreme Court dismissed
the petition in the first case and granted the petition in the second case.

E. MICHAEL & Co. INC., V. ENRIQUEZ, G.R. No. L-10824, DECEMBER

24, 1915

FACTS:
The legal dispute arose from a transaction where Enriquez sold property to
E. Michael and E. Michael & Co., Sociedad en comandita, with a right of
repurchase. The latter asserted itself as the successor through a legally
executed instrument transferring property, business, and assets, including
the concerned land. The claim was based on the expiration of the repurchase
period, leading to the consolidation of the title in favor of E. Michael & Co. To
substantiate its case, E. Michael & Co. attempted to demonstrate the proper
execution of the sale instrument with a right of repurchase, emphasizing
that the document had been lost. However, this attempt faced objections,
and the court upheld these objections.

ISSUE:
Whether or not the lower court made a mistake by rejecting E. Michael &
Co.'s attempt to establish the proper execution and delivery of the sale
instrument with a right of repurchase, emphasizing that the document is
lost.

RULING/DECISION:
The lower court made an error in refusing to admit proof of due execution,
delivery, and subsequent loss of the instrument. Lower courts are correct in
rejecting incompetent evidence. To be admissible, evidence on the contents
of written instruments requires producing and proving the original writing,
with exceptions. The document's loss must be proven, after which evidence
of its contents can be established. Proof of execution, delivery, and loss
involves various criteria, and once established, evidence of contents may be
presented through specific means. Objections in the lower court were
sustained due to the counsel's characterization of the instrument, resulting
in the court erroneously cutting off counsel. Despite this, a new trial is
deemed necessary.

EAGLERIDGE DEVELOPMENT CORP. V. CAMERON GRANVILLE 3 ASSET

MANAGEMENT, INC., G.R. No. 204700, NOVEMBER 24, 2014

FACT:
The current matter involves the motion for reconsideration filed by
respondent Cameron Granville 3 Asset Management, Inc. in response to the
Supreme Court's decision, which reversed the CA's resolutions. The Supreme
Court directed the respondent to produce the Loan Sale and Purchase
Agreement (LSPA) dated April 7, 2006, along with its annexes or
attachments, for the petitioners to inspect or photocopy. The motion for
reconsideration argues three main points: (1) the untimeliness of the motion
for production, (2) the potential violation of the Parole evidence rule through
LSPA production, and (3) the privileged and confidential nature of the LSPA
under the Special Purpose Vehicle Act. Petitioners Eagleridge Development
Corporation, Marcelo N. Naval, and Crispin I. Oben submitted their motion to
admit an attached opposition on June 7, 2013. Subsequently, respondents
filed a reply, and petitioners submitted a motion to admit an attached
rejoinder.

ISSUE:
Whether or not the discovery mode allowing production/inspection of
documents can be utilized even after the pre-trial stage, provided there is a
demonstrated good cause.

RULLING/DECISION:
Certainly. The utilization of the discovery mode for the production or
inspection of documents, such as through a motion for production, is not
confined to the pre-trial stage. Rule 27 of the 1997 Rules of Court does not
prescribe a specific timeframe for employing this discovery method,
requiring only court permission "upon due application and a showing of due
cause." The Loan Sale and Purchase Agreement (LSPA) is pertinent to the
dispute over the validity of the deed of assignment, a key issue raised by
petitioners in the trial court. Permitting its production and examination aligns
with the objectives of the discovery rules. The lack of significant practical
difficulties on the part of the respondent to present the document for
inspection, coupled with the continuous failure to assert such difficulties,
underscores the importance of allowing petitioners access to relevant
evidence and upholding their fundamental right to due process.

AIR PHILIPPINES CORP. V. PENNSWELL, INC., G.R. No. 172835,

DECEMBER

FACTS:
Air Philippines Corporation (petitioner) and Pennswell, Inc. (respondent) are
embroiled in a legal dispute over outstanding payments for supplied goods.
The petitioner alleges fraud in a previous transaction, claiming deceptive
practices by the respondent. Despite an initial agreement for a refund, a
demand for payment led to the respondent filing a Sum of Money complaint.
During the trial, the petitioner sought chemical details of specific products,
initially granted by the RTC but later reversed, citing trade secrets. The
Court of Appeals upheld this decision, prompting the petitioner to appeal to
the Supreme Court.

ISSUE:
Whether or not the Court of Appeals made a mistake in supporting the RTC's
decision that rejected the petitioner's motion to compel the disclosure of the
respondent's product details.

RULING/DECISION:
The case involves a dispute between Air Philippines Corporation (petitioner)
and Pennswell, Inc. (respondent). The respondent supplied goods to the
petitioner, leading to an outstanding obligation. The petitioner claimed fraud
in a previous sale, alleging that the respondent deceptively altered product
information. After a meeting to resolve the issue, the respondent demanded
payment for the outstanding obligation, resulting in a complaint. During the
trial, the petitioner sought to compel the respondent to disclose detailed
chemical information about its products. Initially granted, the order was later
reversed, with the respondent arguing that the information constituted a
trade secret. The Supreme Court upheld the Court of Appeals' decision,
affirming the RTC's finding that the chemical composition was a trade secret
deserving legal protection. The Court emphasized that trade secrets and
banking transactions are exceptions to the right to information, and their
disclosure is not mandated. The Court highlighted the unique and
confidential nature of the respondent's product formulation, emphasizing the
greater protection trade secrets deserve. Revealing such information would
not contribute to the case's resolution, which primarily involves a sum of
money. Ultimately, the Court ruled in favor of protecting the respondent's
trade secrets.

People v. Ochoa, G.R. No. 173792

FACTS:
Rosario Ochoa faced charges of illegal recruitment in large scale for
recruiting individuals for jobs in Taiwan or Saudi Arabia without the required
license, along with three counts of estafa for collecting a total placement fee
of P124,000. Witnesses, including Cory Aquino from the POEA, testified, and
a certification confirmed Ochoa's lack of authorization for overseas
recruitment. Ochoa claimed employment with AXIL International Services
and Consultant, which had a temporary license, admitting to recruiting and
collecting fees but contending she remitted the funds to AXIL's manager.
The RTC and CA found Ochoa guilty of illegal recruitment and estafa.

ISSUE:
Whether or not was Ochoa found culpable of engaging in large-scale illegal
recruitment.

RULING/DECISION:
The Supreme Court ruled negatively on the first issue concerning Republic
Act No. 8042. However, it affirmed the affirmative stance on the second and
third issues. Establishing illegal recruitment necessitates demonstrating that
the appellant created a clear impression of having the authority to send
individuals abroad for work, leading them to believe they needed to part
with their money for employment. All eight complainants consistently
testified that Ochoa promised them overseas employment, collecting their
biodata, birth certificates, and passports, along with various fees. Despite
their compliance, the complainants were unable to secure overseas work,
and Ochoa failed to return the money despite their pleas.

DST Movers Corp. v. People’s General Insurance Corp., G.R. No.

198627
FACTS:
PGIC filed a Sum of Money complaint alleging that on February 28, 2002, an
Isuzu Elf truck owned by DST Movers hit a Honda Civic sedan, causing
damage. PGIC relied on a Traffic Accident Investigation Report by PO2
Cecilio Grospe Tomas as evidence. The sedan, covered by PGIC's insurance,
led to a total loss claim of P320,000. PGIC, having paid this amount to the
sedan's owner, Fidel Yuboco, sought P90,000 from DST Movers. DST Movers,
claiming its truck was under repair on the alleged date, presented invoices
and receipts. Despite the defense, the Metropolitan Trial Court ruled in favor
of PGIC, a decision upheld by the RTC and CA. DST Movers contested this,
arguing that its liability was not proven by a preponderance of evidence,
criticizing reliance on the Traffic Accident Investigation Report as improperly
identified and uncorroborated.

ISSUE:
Whether it was a mistake for the Metropolitan Trial Court to accept and
attribute evidentiary value to the primary piece of evidence relied upon by
the respondent, People's General Insurance Corporation, which is the Traffic
Accident Investigation Report prepared by PO2 Tomas.

RULING/DECISION:
The Metropolitan Trial Court made an error by accepting and giving
evidentiary weight to the Traffic Accident Investigation Report, the main
piece of evidence relied upon by the People's General Insurance Corporation.
The report lacked the necessary requisites for admissibility, as the person
who prepared it, PO2 Tomas, did not have personal knowledge of the facts
stated. The report was based on information reported by "G. Simbahon of
PNCC/SLEX," who possessed the relevant knowledge. Consequently, even if
the report had been admitted as evidence, it would not have been sufficient
to establish the identity of the motor vehicle or the person responsible for
the damage sustained by the sedan.

Estrada v. Desierto, G.R. No.146738, April 3, 2001

FACTS:
mid corruption accusations, Joseph Estrada's presidency in the Philippines
faced an impeachment trial in 2000. Key figures called for his resignation,
leading to mass protests. As the trial progressed, Estrada's attempt to
appease public sentiment failed, culminating in his conceding his incapacity
to fulfill presidential duties. Gloria Macapagal-Arroyo assumed the role of
acting president, gaining acceptance from various sectors. The Office of the
Ombudsman pursued corruption charges against Estrada, who sought to halt
legal proceedings until his term ended. The Supreme Court clarified the
status quo regarding the presidency and set limitations on public discussion
of the case's merits.

ISSUE:
Whether or not the presented petitions pose legal questions fit for court
resolution, Determining Estrada's status as either a President on leave or
Arroyo's role as the Acting President, Analyzing the necessity of an
impeachment conviction as a prerequisite for Estrada's criminal prosecution
and addressing potential immunity from criminal charges and evaluating the
possibility of halting Estrada's prosecution due to prejudicial publicity.

RULLING/DECISION:
The petitions before the court involve legal, not political, matters and
therefore constitute a justiciable controversy falling within the court's
jurisdiction. The notion of 'political questions' refers to issues designated for
the people's decision or falling under the discretionary authority of the
legislative or executive branches. Arroyo's government, bound by the 1987
Constitution, isn't revolutionary, and events like EDSA II are deemed an
expression of people's power within constitutional limits, subject to judicial
review regarding Estrada's resignation and Arroyo's succession.
Regarding Estrada's status, the argument that he isn't a President on leave
while Arroyo acts as President hinges on the fact that, as per Section 11,
Article VII, only Congress holds the authority to determine a President's
incapacity to perform duties. Congress' recognition and support of Arroyo
implies a rejection of Estrada's claim, with the Court refraining from revising
Congress' decision due to the principle of separation of powers.
Estrada's claim of immunity from suits due to lack of conviction in the
impeachment case faces scrutiny. The executive immunity provision from
the 1973 Constitution isn't present in the 1986 Constitution, allowing for
suits against former presidents post-resignation.
Lastly, Estrada's bid to stop the Ombudsman's investigation based on
prejudicial publicity and alleged bias faces legal precedent. Precedents
establish that an accused's fair trial isn't incompatible with a free press,
provided the media remains responsible. Judges are deemed capable of
discerning the law despite media exposure, ensuring impartiality during
proceedings.

People v. Cachuela, G.R. No. 191752, June 10, 2013

FACTS:
The National Bureau of Investigation received information linking a group,
led by Cachuela, to a robbery and murder at WSC, along with their
purported involvement in firearms trading. An entrapment team was formed
by the NBI. Nabilgas surrendered to the police, providing details of other
participants. Cachuela and Ibañez were arrested by NBI agents in an
entrapment operation. Zaldy identified the accused during a police line-up as
involved in the WSC robbery and the murder of an employee. Nabilgas also
confessed in writing, implicating the accused. The prosecution filed charges
for robbery with homicide against the accused. After pleading not guilty, the
trial commenced. Zaldy passed away during this period. The trial court found
the accused guilty of robbery with homicide, a ruling upheld by the Court of
Appeals.

ISSUE:
Whether or not the conviction was based on Zaldy's identification outside the
courtroom and his confession given outside formal legal proceedings.

RULING/DECISION:
Zaldy identified the accused during a police line-up as involved in the WSC
robbery and Rex's killing but didn't testify in court due to being at the
National Center for Mental Health and passing away during the trial. Courts
use a totality of circumstances test for out-of-court identifications,
considering factors like the witness's view of the suspect during the crime,
attention level, accuracy of prior descriptions, certainty, time passed, and
procedure fairness. However, Lino's account lacked essential details about
the identification process, making Zaldy's identification unreliable. Missing
specifics hindered evaluating factors like witness certainty and the
identification's fairness. Also, the absence of Zaldy's in-court identification
added to the uncertainty. Regarding extrajudicial confessions, courts require
voluntariness, counsel presence, an express statement, and a written
confession for admissibility.