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G.R. No.

199270, October 21, 2015 of the truth of such entries, for these are often incomplete and
inaccurate. These, therefore, should not be given undue significance
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. VERGEL or probative value as to the facts stated therein.
ANCAJAS AND ALLAIN* ANCAJAS, Accused-Appellants.
BEST EVIDENCE RULE
On October 19, 1998, appellants were charged and convicted with
the crime of Rape for having carnal knowledge with 19 year-old AAA REPUBLIC vs. MUPAS
without the latter’s consent. It appears further that in order to do
DOTC awarded the construction and development of the NAIA-IPT
so, Vergel Ancajas boxed AAA on the stomach thereby rendering her
unconscious. When AAA regained her consciousness, she noticed III under a build-operate-and-transfer arrangement to Paircargo
that she was only wearing her t-shirt, her body was in pain, and her Consortium. Later on, the latter organized itself as PIATCO. A
Concession Agreement was then entered with PIATCO where the
vagina was covered with blood. She then went back to her
employers' house to tell them about the incident. Her employers latter was to build, operate, and maintain the NAIA-IPT III during the
then accompanied her to the police station in Bogo, Cebu to report concession period of 25 years. A series of suits ensued. One of
the rape incident. Said incident was contained in a police blotter. which is a complaint by the Government for the expropriation of the
NAIA-IPT III. RTC evenutally issued a writ of possession in favor of
Notably, a notation of the police blotter reflects that “ xxx the
alleged suspects were Allain Ancajas and Vergel Ancajas and [AAA] the Government.
refused (sic) the other suspects.” PIATCO then presented an appraisal of NAIA-IPT’s replacement
Appellants thus contented that if AAA was positive as to their costs, including its attendant costs which include photocopies of
identification as the perpetrators of the crime charged, why were numerous documents, and the validation of PIATCO’s computation
of attendant costs prepared by Reyes Tacandong& Co., among
there two other names included in the police blotter?
others.
ISSUE: WON the appellants’ argument is meritorious.
When the case eventually reached the CA, the latter arrived at its
HELD: NO. own formula of the NAIA-IPT III’s replacement cost. It likewise
observed that PIATCO’s summarized computation of attendant
The inclusion of the two additional names was cured by the sworn
costs was self-serving and unsubstantiated by relevant evidence.
statement of AAA and her categorical declaration in open, court
that appellants were the perpetrators of the crime charged and no PIATCO then argued that its non-submission of original documents
other. Entries in a police blotter, although regularly done in the before the trial court is justified under Section 3 (c), Rule 130 of the
course of the performance of official duty, are not conclusive proof ROC.
ISSUE: WON PIATCO’s non-submission of original copies is fatal to averred that the respondents have no legal capacity to institute said
its cause. action on the ground that they are illegitimate children of
Anastacio, Sr. As such, they have no right over Silvestra's estate
Held: YES. pursuant to Article 992, NCC. In order to prove their legitimate
Whenever a party seeks an exemption under the best evidence rule filiation, the respondents presented their respective Certificates of
pursuant to Section 3 (c), Rule 130, he asks permission from the trial Live Birth issued by the NSO.
court to produce a summary of numerous documents, whose Calimag then contended that said documents do not conclusively
originals are available to the adverse party for inspection. He does prove the respondents' legitimate filiation since they contain no
not ask permission from the trial court to present in evidence the entry stating whether the respondents are of legitimate or
numerous non-original documents. illegitimate filiation. Moreover, Calimag argued that the certificates
Thus, if a party desires to present photocopies of the original of live birth were not signed by Anastacio, Sr. She argues that the
documents, he must first establish that the presentation of birth certificate must be signed by the father in order to be
photocopies is justified under Section 3 (a), (b), and/or (d), Rule 130. competent evidence to establish filiation, whether legitimate or
He must establish the presence of all the elements under these illegitimate.
provisions. In this case, however, PIATCO failed to establish that the ISSUE: WON Calimag’s contentions are tenable.
photocopied documents fall under Section 3 (a), (b), and/or (d),
Rule 130 of the Rules of Court. These photocopied documents are HELD: NO.
hearsay evidence. They are mere scraps of paper and have no
"A certificate of live birth is a public document that consists of
weight as basis for the attendant costs of the NAIA-IPT III.
entries regarding the facts of birth in the Civil Registry made in the
G.R. No. 191936, June 01, 2016 performance of a duty of the Civil Registrar. Thus, being public
documents, the respondents' certificates of live birth are presumed
VIRGINIA D. CALIMAG, Petitioner, v. HEIRS OF SILVESTRA N. valid, and are prima facie evidence of the truth of the facts stated in
MACAPAZ, REPRESENTED BY ANASTACIO P. MACAPAZ, JR.,
them.
Respondents.
The petitioner's assertion that the birth certificate must be signed
On March 2, 2006, herein respondents, asserting that they are the by the father in order to be a competent evidence of legitimate
heirs of Silvestra Macapaz, instituted an action for Annulment of filiation does not find support in law and jurisprudence. Verily,
Deed of Sale and Cancellation of TCT with Damages against Virginia under Section 5 of Act No. 3753,46 the declaration of either parent
Calimag and the Register of Deeds of Makati City. Calimag then
of the new-born legitimate child shall be sufficient for the
registration of his birth in the civil register.

GR No. 202514, Jul 25, 2016

ANNA MARIE L. GUMABON v. PHILIPPINE NATIONAL BANK

On August 12, 2004, Anna Marie filed a complaint for recovery of


sum of money and damages against PNB and the PNB Delta branch
manager Silverio Fernandez. The case stemmed from the PNB's
refusal to release Anna Marie's money in a consolidated savings
account and in two foreign exchange time deposit. PNB argued that
Anna Marie is not entitled to be paid mainly because she already
withdrew and used the funds in her account. The bank presented
photocopied documents to substantiate its claim.

In her reply, Anna Marie argued that the best evidence of her
withdrawals is the withdrawal slips duly signed by her and the
passbooks pertaining to the accounts. PNB, however, failed to show
any of the withdrawal slips and/or passbooks, and also failed to
present sufficient evidence that she used her accounts' funds.

ISSUE: WON PNB’s failure to present the original copies of Anna


Marie’s transactions is fatal to its cause.

HELD: YES.