CASE DIGEST IN EVIDENCE

ATTY. TET OCAMPO

PATRICIA ANN CAPUDOY
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
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
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. CUDAL G.R. No. 167502
PEOPLE V. OCHOA, G.R. No. 172792
DST MOVERS CORP. V. PEOPLE’S GENERAL INSURANCE CORP., G.R. No.
198627
PEOPLE V. UMAPA, G.R. No. 215742
WEEK 10: ADMISSION VS CONFESSION
ESTRADA V. DESIERTO, G.R. No. 146738, APRIL 3,2001
PEOPLE V. CACHUELA, G.R. No. 191752, JUNE 19, 2013
PEOPLE V. SABAS POYOS, G.R. No. L-63861 AUGUST 19,1986
PEOPLE V. SATORRE, G.R. No. 133858, AUGUST 12,2003
 STONEHILL V. DIOKNO G.R. No. L-19550 June 19, 1967
FACT:
Petitioners, along with their corporation facing pending deportation cases,
were accused of violating various laws. Four search warrants were issued,
authorizing any peace officer to search the premises of petitioners' offices,
warehouses, and residences for specific documents related to their business
transactions and other relevant materials. The seized items were categorized
into those found in corporate offices and those in petitioners' residences.
Petitioners contested the legality of the warrants, arguing, among other
things, the lack of particularity, the unauthorized seizure of cash, and the
alleged fishing expedition to gather evidence for deportation cases. They
also claimed that the searches were conducted illegally and that the seized
items were not properly turned over to the issuing courts. Respondent-
prosecutors cited the Moncado vs People’s Court precedent, asserting that
even if the searches were unconstitutional, the seized items remain
admissible as evidence against the petitioners. The main issue revolved
around the validity of the search warrants.
The Supreme Court ruled in favor of Stonehill et al., overturning the
Moncado doctrine. Despite acknowledging that Stonehill et al. may not be
the appropriate parties to challenge the search warrants issued against their
corporation, as corporations have distinct personalities from individuals, the
Court emphasized the illegitimacy of the three warrants issued.

ISSUE:
Whether or not the pivotal inquiry revolves around the validity of the issued
search warrant.

RULING/DECISION:
Yes, the Supreme Court sided with Stonehill et al., overturning the Moncado
doctrine. Although Stonehill et al. are not the appropriate parties to
challenge the validity of the search warrant against their corporation, lacking
a cause of action (only officers or board members of the corporation may
contest the warrant, given that corporations have distinct personalities from
the petitioners), the three warrants issued to search the petitioners'
residences are declared null. Consequently, the searches and seizures
conducted in those locations are deemed unlawful.
The constitution safeguards individuals against unreasonable search and
seizure, stipulating that warrants should only be issued upon probable cause
determined by the judge and should specifically describe the items to be
seized. In this case, these requirements were not met. The warrant was
based solely on an allegation that petitioners committed a "violation of
Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code), and
Revised Penal Code." Without specifying a particular violation, the judges
who issued the warrants lacked a basis for finding probable cause, as it
necessitates credible evidence of the alleged misconduct. Convicting
someone of a generic offense without reference to specific legal provisions is
considered a legal error.
The court emphasizes the elimination of general warrants, asserting that the
invalidity of the warrant is unaffected by the legality or illegality of
petitioners' transactions. The broad language used in the warrant,
encompassing various documents related to business transactions, violates
the constitutional injunction against unreasonable searches and seizures.
The court underscores that the protection afforded by constitutional
amendments, such as the Fourth Amendment, loses its value if private
documents can be seized and used as evidence against a citizen accused of
an offense. The court warns against compromising fundamental principles
established in the Constitution for the sake of expediting the pursuit of
justice.

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

FACT:
In March 2009, there were reports of pimps offering sexual services to
young girls at the X Lodge, owned by Planteras, Jr. and his wife, Christina
Planteras. Surveillance conducted on March 19, 2009, by PO3 Jose Erwin
Dumaguit and PO1 Arnold Rusiana, using a concealed camera, revealed
Marlyn Buhisan at the lodge offering girls for sex. Subsequently, an
entrapment operation on April 28, 2009, caught Marichu Tawi offering sexual
favors to girls at the X Lodge. During negotiations involving marked money,
Planteras, Jr. appeared to be aware of the transaction. The police officers,
along with the introduced girls, made arrests. Planteras, Jr. faced charges for
violating Section 5, par. (a) of Republic Act No. 9208, about promoting
trafficking in persons. The Regional Trial Court (RTC) convicted him, a
decision upheld by the Court of Appeals (CA).

ISSUE:
Whether or not the central inquiry revolves around the question of whether
Planteras Jr. is to be held responsible for the alleged offense he is accused of
committing.

RULING/DECISION:
Yes Indeed, there is indisputable evidence establishing Planteras, Jr. as the
owner and operator of the X Lodge. The presented evidence further indicates
that the individuals engaged in unlawful activities near the lodge, such as
pimps, customers, and prostitutes, utilized the establishment for their illicit
purposes. The prosecution successfully demonstrated Planteras, Jr.'s
awareness of the illicit activities taking place within his property, notably
emphasized by AAA's testimony.
The prosecution's presentation of comprehensive circumstantial evidence
compellingly shows that Planteras, Jr. allowed his establishment to be used
in facilitating human trafficking.
As for Planteras, Jr.'s argument that AAA willingly participated in prostitution,
thereby negating any trafficking charges, such a defense is unfounded.
According to R.A. 9208, the consent or knowledge of a minor is not a valid
defense. The victim's consent becomes irrelevant when coercive, abusive, or
deceptive means are employed in human trafficking activities.
PEOPLE V BERNAL, G.R. NO. 113685, JUNE 19, 1997
FACT:
Theodore Bernal, along with two unidentified individuals, faced charges of
kidnapping, as outlined in the information that alleged their armed abduction
of Bienvenido Openda, Jr. on August 5, 1991, in Davao City. Bernal pleaded
not guilty, and during the trial, the prosecution presented four witnesses,
while Bernal testified in his defense.
On the mentioned date, Bernal, Racasa, and Openda, Jr. We’re drinking
together when two men arrived, identified Openda, Jr., and proceeded to
handcuff and take him away, claiming to be policemen. According to Bernal,
he left the scene shortly to fetch his child. The prosecution contended that
the motive behind the kidnapping was Openda, Jr.'s alleged affair with
Bernal's wife, Naty, as per the testimony of Salito Enriquez. Openda, Jr.
remained missing.
In defense, Bernal asserted that Openda, Jr. was arrested by the police on
August 5, 1991, for drug-related charges and was not kidnapped. Despite
this, the RTC found Bernal guilty of kidnapping, sentencing him to reclusion
perpetua and ordering him to indemnify Openda's mother. Bernal contested
the verdict, challenging the lower court's reliance on what he deemed as
questionable testimonies and the failure to establish his guilt beyond
reasonable doubt.

ISSUE:
Whether or not Bernal is guilty of the crime of kidnapping is the essential
question.

RULING/DECISION:
No, compelling reason to overturn the decision of the lower court. In this
case, it is uncontested that Bernal collaborated with two unidentified
individuals, evident from their synchronized actions indicating a shared
intent and purpose. The establishment of conspiracy often relies on a series
of circumstances, and the facts in this situation strongly indicate Bernal's
participation in Openda, Jr.'s disappearance.
Considering Openda, Jr.'s prolonged absence following the abduction, his
testimony is unavailable. However, his admission to Enriquez regarding his
inappropriate relationship with Bernal's wife holds admissibility as evidence.
This confession, being a statement against Openda Jr.'s interests due to the
criminal nature of the affair, is deemed permissible in court. It is reasonable
to assume that a mentally sound individual would not falsely incriminate
themselves.
Hence, based on these considerations, the present appeal is denied, and the
decision rendered on November 18, 1993, is affirmed in its entirety. All costs
are imposed on the accused-appellant, Theodore Bernal.
 REVILLA V. COURT OF APPEALS (217 SCRA 583, 1993)
FACT:
Don Cayetano Revilla, an unmarried individual, possessed two parcels of
land with structures in Manila and six land parcels in his hometown in
Bulacan, totaling a value of P30 million. In 1978, he drafted a 13-page last
will, distributing his entire estate among his nine nephews and nieces,
including petitioner Heracio Revilla. Each heir was to receive a 1/10 share,
with the final tenth reserved for masses to be conducted posthumously and
for the maintenance of religious images in a Bulacan chapel.
During Don Cayetano's lifetime, he sought probate for his will, which the
Court of First Instance (CFI) Manila admitted. Unfortunately, a fire at the
Manila City Hall destroyed records, prompting a petition for the
reconstitution of said records, which was granted.
Following Don Cayetano's demise, Heracio Revilla filed another petition,
presenting a will allegedly executed in 1982, naming himself as the sole heir
and executor. However, Heracio's eight siblings opposed the probate, citing
several grounds:
Don Cayetano never indicated revocation of the 1978 will from 1978 until his
death.
The 1982 will did not adhere to legal execution requirements, and
Cayetano's signature differed from his customary one.
Don Cayetano was mentally unsound when he created the will.
The alleged will was executed under undue pressure and influence.
The 1978 will was deemed void due to alleged duress, fear, or threats during
its execution.
Don Cayetano acted by mistake, and the signatures in the purported will
were obtained through fraud, with no intention for the document to serve as
his will during the signing.
The trial court rejected the second will, and upon appeal, the Court of
Appeals (CA) affirmed the trial court's decision.

ISSUE:
Whether the court made a mistake in rejecting the validity of the second will.

RULING/DECISION:
Yes, Don Cayetano testified during the reconstitution proceedings that he
was unaware that the second will be attributed to him. He affirmed the
authenticity of his first will and asserted that it was his sole and genuine
testament. His physical condition during the alleged execution of the second
will, a period when he was hospitalized for two months, was cited as
evidence that he could not have signed any documents during that time.
The reconstitution proceedings involved the presentation of the will, enclosed
in a browned envelope labeled "Buksan ito pagkalibing ko," which Cayetano
agreed to open. He recognized the original will, stating that he had indeed
signed it. In his court declarations, Cayetano explicitly denied executing any
additional last will after the probate of his original will.
It is crucial to note that, despite opposing the reconstitution of Don
Cayetano's first will, the petitioner did not disclose the existence of the
second will allegedly made just two months before the reconstitution
proceedings. If the second will already have been in existence in November
1982, it would have been a potent argument against reconstituting the
probate of the first will.
the circumstances, it appears that the execution of the second will, dated
September 13, 1982, was unlikely due to Don Cayetano's hospitalization
during that period. Instead, it is suggested that the document may have
been procured when the testator was secluded and effectively isolated, as
supported by a court order requiring the petitioner to allow Don Cayetano's
siblings to visit him. A videotape from the visit contradicted the petitioner's
claims about Don Cayetano's sentiments towards his nephews and nieces.
Despite the court order, the petitioner continued efforts to isolate Don
Cayetano, eventually transferring him from his house in Manila to the
petitioner's house in Quezon City. This environment of secrecy and seclusion,
coupled with the exclusion of eight other heirs from the second will, led the
trial court and the Court of Appeals to conclude that undue influence was
exerted by the petitioner over Don Cayetano.
Furthermore, the court found evidence of fraud, as Don Cayetano was not
informed that the document he signed, alongside witnesses Co, Barredo, and
Lim, was a second will be revoking the dispositions made in his first will. The
omission of the provision reserving one-tenth of his properties for religious
purposes in the second will raise doubts about its authenticity. Even if one
assumes the execution of the second will, the testimonies of the notary
public and the three instrumental witnesses were discredited due to
significant contradictions in their statements.

PEOPLE V TUNDAG, G.R. Nos. 135695-96, OCTOBER 12, 2000

FACT:
Mary Ann Tundag has lodged two distinct complaints accusing her father,
Tomas Tundag, of committing incestuous rape when she was 13 years old. In
her testimony, she asserted that her father used a knife to intimidate her
into silence during the rapes that took place on September 5, 1997, and
November 7, 1997. After the second incident, Mary Ann sought guidance
from a neighbor and subsequently reported the matter to the police.
Despite being informed of the potential death penalty for her father if found
guilty, Mary Ann's testimony remained consistent. Supporting her claims,
medical examinations revealed lacerations in her hymen. The alleged offense
falls under Section 335 of the Revised Penal Code, as amended by Section
11 of R.A. No. 7659, categorizing the rape of a minor daughter by her father
as a qualified and heinous crime. To establish the crime of rape, the
prosecution must prove the elements of sexual congress with a woman by
force or without her consent. Additionally, for the imposition of capital
punishment, it is necessary to establish that the victim is under 18 years old
at the time of the rape and that the offender is a parent of the victim. While
it was adequately proven that the offender was the victim's father, the
victim's age was not conclusively established beyond a reasonable doubt.

ISSUE:
Whether or not determining the appropriateness of taking judicial notice in
this instance is a matter that warrants careful consideration.

RULING/DECISION:
No, the appropriateness of judicial notice is not applicable in this scenario.
Judicial notice involves acknowledging facts that judges can recognize
without requiring further evidence due to their common knowledge.
According to Rule 129, Section 3, a hearing is necessary, especially for
matters like determining age, before courts can take judicial notice.
Typically, the age of the victim can be established through the presentation
of birth or baptismal certificates. If these documents are unavailable, proof
of their loss or destruction can be provided through other documentary
evidence or oral testimony sufficient for the purpose.
Failure to adequately prove the victim's age independently poses a barrier to
securing a conviction for rape in its qualified form. It is crucial to present
independent proof of the actual age of a rape victim to dispel any
uncertainty about whether the case falls under qualifying circumstances that
warrant the imposition of the death penalty, as mandated by law.
Congress recognizes the father-daughter relationship as a special
circumstance that requires the imposition of the death penalty. However, in
the present case, even though the special qualifying circumstance of the
relationship was proven, there was a lack of evidence concerning the
minority of the victims. As a result, this absence excludes the case from the
mandatory death sentence requirement.