G.R. No. 200065 - Capital Shoes Factory, Ltd. vs. Traveler Kids, Inc.

Capital Shoes Factory Ltd. (CSFL), a foreign corporation manufacturing children's shoes, and Traveler Kids, Inc. (TKI), a domestic corporation engaged in manufacturing, importing, and distributing shoes, entered into an agreement in 2000.
The agreement provided that TKI would import shoes and sandals made by CSFL's factory in China, with TKI placing purchase orders based on special designs and specifications. CSFL would manufacture and ship the goods accordingly.
Payment terms required TKI to pay 30% via letters of credit and the remaining 70% by telegraphic transfer 30 days after delivery.

TKI initially complied with payment terms for about three years but began defaulting in 2004.
CSFL granted concessions and extensions and accepted partial payments, but as of July 10, 2005, TKI's unpaid accounts amounted to US$325,451.39, excluding interest. Additionally, CSFL manufactured $92,000.00 worth of shoes based on subsequent purchase orders.
CSFL sent both verbal and written demand notices for payment, which went unheeded. Consequently, CSFL filed a complaint before the Regional Trial Court (RTC) for collection of sum of money and damages.

During trial, CSFL identified several sales invoices and order slips as evidence of transactions with TKI. TKI objected to their admission on the ground that they were photocopies.
TKI also objected to evidence supporting attorney’s fees, claiming the issue was not raised during the pre-trial conference.
After the presentation of CSFL's last witness, CSFL filed a Formal Offer of Exhibits including the contested documents. TKI reiterated objections citing inadmissibility because of photocopy status and the attorney’s fees issue.

On May 13, 2011, RTC admitted all the offered exhibits, finding the objections insufficient to exclude the documents and allowing the inclusion of evidence for attorney’s fees.
TKI filed a motion for reconsideration which the RTC denied on June 23, 2011, affirming that the sales invoices and order slips were duplicate originals sufficiently established by CSFL's witness Ms. Susan Chiu’s testimony, and that attorney’s fees issues were impliedly included in the complaint.
Instead of presenting evidence, TKI filed a petition for certiorari with the Court of Appeals (CA) arguing improper admission of photocopies and irrelevant attorney’s fees documents. The CA did not issue any injunction; the RTC ordered TKI to present evidence, but TKI refused, resulting in the RTC considering TKI’s right to present evidence waived and ordering CSFL’s memorandum submission.
On October 5, 2011, the CA partially granted TKI’s petition, affirming the RTC orders but modifying them by excluding specific exhibits (Exhibits aDa to aGG-1a and aHHa to aKK-1a) for being mere photocopies without proven exceptions under Section 3, Rule 130 of the Rules of Court.
The CA upheld the admission of evidence related to attorney’s fees. CSFL’s motion for partial reconsideration before the CA was denied on January 16, 2012.

CSFL filed a petition for review challenging the CA’s exclusion of certain exhibits.
CSFL contended the excluded documents were duplicate originals, prepared simultaneously as originals, and their admission was proper.
TKI maintained that CSFL’s claim was unilateral and without supporting evidence, thus inadmissible.

Whether the Court of Appeals erred in excluding the sales invoices and order slips denominated as Exhibits aDa to aGG-1a and aHHa to aKK-1a for being mere photocopies in violation of the Rules of Evidence and whether these documents should have been admitted as duplicate originals.

Whether the Court of Appeals gravely erred in going beyond its jurisdictional limits by reevaluating the facts and evidence admitted by the RTC.