People v. Lastimosa (G.R. No. 265758)
February 3, 2025.
Nature of the Case:
Criminal appeal raising, among others, the admissibility and evidentiary value of duplicate copies of documents under the Rules on Evidence.
I. Core Ratio Decidendi on Duplicate Copies as Evidence
1. Duplicate Originals Are Admissible Without Need to Produce the “Original”
The Court reaffirmed the modern rule under the Best Evidence Rule (Rule 130, 2019 Amendments):
A duplicate is admissible to the same extent as the original unless:
a) a genuine question is raised as to the authenticity of the original; or
b) it would be unjust or inequitable to admit the duplicate in lieu of the original.
A duplicate includes copies produced by mechanical, photographic, electronic, or other equivalent processes that accurately reproduce the original.
Ratio: The Rules no longer demand the ritualistic production of a single “original” when reliability is not genuinely in dispute. What the law protects is authenticity, not formalism.
2. Burden of Raising a Genuine Question on Authenticity
The Court emphasized that mere objection is insufficient. The party opposing admission must raise a specific and substantiated challenge to authenticity.
Ratio: The evidentiary system presumes regularity and authenticity in documentary evidence unless the challenger discharges the burden of showing a real issue. Bare allegations do not bar admissibility.
3. Distinction Between Admissibility and Weight
Even if admitted, the probative value of duplicate evidence remains subject to evaluation by the trial court.
Ratio: Admissibility concerns competence; weight concerns credibility. Once admitted, documentary duplicates may still be discounted if the surrounding circumstances cast doubt on reliability.
4. No Violation of the Accused’s Constitutional Rights
The admission of duplicates does not, by itself, violate the accused’s right to due process or confrontation, provided:
The source and authenticity are established;
The accused had opportunity to cross-examine the witness identifying the document.
Ratio: Constitutional safeguards focus on fairness of the adversarial process, not on rigid evidentiary formalism.
5. Judicial Notice of Modern Documentary Reproduction
The Court acknowledged contemporary realities: documents are routinely generated, transmitted, and stored electronically.
Ratio: The Rules on Evidence must be interpreted in harmony with technological developments. The justice system cannot be anchored to archaic notions of documentary proof.
6. Application to Criminal Proceedings
The Court clarified that the rules on duplicates apply equally in criminal cases, subject to the higher standard of proof beyond reasonable doubt.
Ratio: While the prosecution bears the burden of proof, evidentiary rules governing documentary admissibility are neutral procedural standards. The quantum of proof affects sufficiency, not admissibility.
II. Ancillary Doctrinal Clarifications
1. The Best Evidence Rule applies only when the contents of a document are the subject of inquiry.
2. If a witness testifies from personal knowledge, production of the document is not indispensable.
3. Secondary evidence rules apply only when the original is unavailable and authenticity is genuinely in issue.
III. Doctrinal Significance
The decision reinforces three institutional principles:
1. Substance over technicality in documentary evidence.
2. Burden allocation discipline — objections must be concrete, not speculative.
3. Procedural modernization consistent with the 2019 Amendments to the Rules on Evidence.
Sources / References
1. People v. Lastimosa, Supreme Court of the Philippines.
2. 2019 Amendments to the Rules on Evidence, Rule 130 (Best Evidence Rule).
3. Article III, Section 14, 1987 Constitution (Rights of the Accused).
Reference:
People v. Lastimosa (G.R. No. 265758)
February 3, 2025.
Assisted by ChatGPT, February 28, 2026.
