G.R. No. 234514 - People vs. Vinas y Maniego

On April 20, 1996, M/V Dibena Win, a foreign-registered vessel owned and operated by Bangpai Shipping Co., allegedly bumped and damaged NPC’s Power Barge 209 at Cebu International Port.
On April 26, 1996, National Power Corporation (NPC) filed a complaint for damages against Bangpai Shipping Co. Before RTC Branch 19, Cebu, NPC later amended its complaint (July 8, 1996) to implead Wallem Shipping, Inc. as an additional defendant, alleging it acted as agent of Bangpai.

Wallem Shipping’s Motion to Dismiss (filed September 18, 1996) was denied on October 20, 1998. Bangpai’s similar motion (filed 2003) was denied on January 24, 2003.
During trial, NPC offered as formal evidence photocopies of Exhibits A–V (including numerous sub-markings) on February 2, 2004.
Bangpai and Wallem objected to the photocopies. On November 16, 2004, RTC Branch 19 issued an Order excluding Exhibits A, C, D, E, H (and sub-markings I, J, K, L, M, N, O, P, Q, R) and Exhibit S (and its sub-markings), applying the best evidence rule and the Rules on Electronic Evidence.
NPC’s Motion for Reconsideration was denied on April 20, 2005.

NPC filed a petition for certiorari under Rule 65 before the Court of Appeals, alleging grave abuse of discretion.
On November 9, 2005, the CA dismissed the petition, holding the trial court acted within its discretion and correctly applied the best evidence rule and the Rules on Electronic Evidence.
NPC then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.

Did the trial court and the Court of Appeals commit grave abuse of discretion amounting to lack or excess of jurisdiction in excluding NPC’s photocopied exhibits?
Do the photocopies constitute “electronic documents” under the Rules on Electronic Evidence and thus qualify as the functional equivalent of originals?