Vda. de Oñate vs. Court of Appeals, 250 SCRA 283, G.R. No.

116149 November 23, 1995

FACTS: Elvira Mato Vda. de Oñate, the original petitioner, was sued by Eulalia M. Taguba in her
capacity as administratrix of the estate of the deceased Leonor Taguba. The dispute centered on Lot
No. 1571, a riceland in Aparri, Cagayan, covered by Transfer Certificate of Title No. T-5168. It was
alleged that Leonor Taguba purchased the land from Elvira Mato Vda. de Oñate in 1976 for
P5,000.00 payable in installments. After full payment was made, a contract was supposed to be
executed, but it was not. The complaint sought specific performance to compel Elvira to execute a
deed of sale in favor of the Taguba estate. The trial court rendered a decision declaring the
agreement between Leonor Taguba and Elvira Mato Vda. de Oñate as a contract of "to sell" and
ordered Elvira to execute the proper document within thirty days. The court also directed the plaintiff
to pursue money claims against Elvira's estate. Elvira's heirs, represented by Maria Mato-Alameda,
Aida Mato, Zoe Mato, Pacita Mato, and Juan Mato II, appealed the decision to the Court of Appeals.
Petitioners appealed to respondent Court of Appeals faulting the trial court's factual findings. They
contended that the trial court erred when it took cognizance of the plaintiff's evidence, particularly
Exhibits "F," "F-1," "F-2" and "F-3" (RECEIPTS), which had been marked but never formally
submitted in evidence as required by the Rules of Court.

ISSUE: Whether the trial court and the Court of Appeals erred in considering evidence, particularly
Exhibits "F," "F-1," "F-2," and "F-3," which were not formally offered in accordance with the Rules of
Court.

RULING: NO. While the exhibits were not formally offered, they were duly identified by testimony
recorded during the trial and incorporated into the records of the case. This satisfies the
requirements for the admission of evidence, as established in jurisprudence. The Court emphasized
that the purpose of formal offer is to allow the parties to examine the evidence and object if
necessary, but in cases where the evidence is duly identified and made part of the records, it may
still be considered. For evidence to be considered, the same must be formally offered. Corollarily,
the mere fact that a particular document is identified and marked as an exhibit does not mean that it
has already been offered as part of the evidence of a party. In Inter-pacific Transit, Inc. v. Aviles, we
had the occasion to make a distinction between identification of documentary evidence and its
formal offer as an exhibit. We said that the first is done in the course of the trial and is accompanied
by the marking of the evidence as an exhibit while the second is done only when the party rests its
case and not before. A party, therefore, may opt to formally offer his evidence if he believes that it
will advance his cause or not to do so at all. In the event he chooses to do the latter, the trial court is
not authorized by the Rules to consider the same. However, in People v. Napat-a citing People v.
Mate, we relaxed the foregoing rule and allowed evidence not formally offered to be admitted and
considered by the trial court provided the following requirements are present, viz: first, the same
must have been duly identified by testimony duly recorded and, second, the same must have been
incorporated in the records of the case. Thus, the trial court and the Court of Appeals did not err in
admitting and considering the exhibits in their decisions.