Facts:
Ybo Lastimosa, initially convicted by the RTC with Homicide for the killing of Ildefonso Vega Jr., was convicted by the Court of Appeals, and his conviction elevated to Murder. Among the many issues he submitted for consideration in his appeal to the Supreme court was propriety of the lower courts admitting in evidence a mere photocopy of Ildefonso’s death certificate, in violation of the Best Evidence Rule.
Issue:
Whether or not the photocopy of the death certificate of Leandro can be admitted in evidence in lieu of the original.
Ruling:
Yes. In so ruling, the Court held that pursuant to Rule 130, Sections 3 and 4 of the 2019 Revised Rules on Evidence, in conjunction with Rule 4, Sections 1 and 2 of the Rules of Electronic Evidence, the duplicate of any original, whether an electronic data message, electronic document, or paper-based document is admissible to the same extent as the original unless (1) a genuine question is raised as to the authenticity of the original, or (2) under the circumstances, it is unjust or inequitable to admit the duplicate in lieu of the original. A photocopy, being a duplicate, is admissible to the same extent as the original absent any genuine questions as to the authenticity of the original or showing that it is unjust or inequitable to admit the duplicate in lieu of the original.
After tracing the evolution of the Best Evidence Rule in its application over the years in the country, as well as in other jurisdictions, the Court held that:
“The 2019 Revised Rules on Evidence modified the title of the Best Evidence Rule to the Original Document Rule, Further, scrutiny of the structure of the current Rule 130, Section 3 and 4 reveals that no evidence is admissible other the original document itself. By express provision, a duplicate, which is defined in Rule 130 Section 3(b), is admissible to the same extent as an original document unless any of the two exceptions are present. It is notable that the definition of a duplicate does not exclude those preproduced from a paper-based original. Accordingly, a duplicate of a paper-based document, under the 2019 Revised Rules on Evidence, is admissible to the same extent as an original except when any of the exceptions are present.
With this, the ruling in MCC Industrial, drawing a dichotomy between the admissibility of duplicates of (a) electronic data message and electronic documents and (b) paper based documents, has been abandoned.
With the advent of the 2019 Revised Rules on Evidence, in conjunction with the Rules on Electronic Evidence, the duplicate of any original, whether an electronic data message, electronic document, or paper-based document, is admissible to the same extent as the original, unless (1) a genuine questions is raised as to the authenticity of the original, or (2) under the circumstances, it is unjust or inequitable to admit the duplicate in lieu of the original.”
People of the Philippines v. Lastimosa, G.R. No. 267758, February 3, 2025