G.R. No. L-16619 - Compania General de Tabacos de Felipinas vs. City of Manila

In Criminal Case No. 36885 before the Court of First Instance of Manila, respondents (Pacita Madrigal-Gonzales, Angelita Centeno, Julia Carpio, Calixto Hermosa, and Crispula R. Pagaran alias Pula) were charged with falsification of public documents.
The charge arose from allegations that the respondents, acting as public officials and employees, fabricated documents to show that relief supplies and/or merchandise were purchased and distributed to calamity victims, when in fact no such distributions were made.

The prosecution introduced a booklet of receipts (marked Exhibit "D") containing blue invoices numbered 101301 to 101400 issued by the Metro Drug Corporation, located at Magallanes corner Jakosalem, Cebu City.
The booklet contained triplicate copies produced by placing two carbon sheets between three sheets of writing paper, ensuring that the original, duplicate, and triplicate copies bore the same information and signatures.
A witness, the salesman responsible for issuing the triplicates (marked as Exhibit "D-1"), testified regarding the process whereby the original invoices were sent to the Manila office, the duplicates given to the customers, and the triplicates retained in the booklet.

The witness confirmed that in the process of preparing receipts, the use of carbon copies automatically produced facsimile copies of the original document.
An additional witness, the accountant of the Metro Drug Corporation in Manila, testified that:

Sales from the provinces were reported to the Manila office, along with corresponding cash journal sheets.
The practice had evolved such that the original white copies were no longer maintained at the central office, as they were given to the customers, with only the duplicate (or pink) copies submitted.

During the trial, while the prosecution was identifying the triplicate invoice (Exhibit "D-1"), the judge in the lower court interrupted the proceedings.
The judge ruled that triplicate copies could only be admitted if it was first proven that the original document was lost and could not be produced.
The judge noted that since the witness testified the original was with the Metro Drug Corporation’s Manila office, the prosecution should have produced the original rather than relying on the triplicates.
The special prosecutor argued that this ruling would adversely affect the integrity of the prosecution’s evidence, as the originals might indeed be unavailable, and thus petitioned for a certiorari against the lower court’s decision.

The prosecution contended that invoices produced by the use of carbon paper—which create duplicate facsimiles of the original—are to be regarded as duplicate originals.
It was argued that these duplicate originals are admissible as evidence without needing to account for the non-production of the original, in line with established legal principles regarding best evidence and duplicate documents.

Whether triplicate documents produced by the use of carbon paper, which serve as duplicate originals, are admissible as evidence without the production of the original document.
Whether the ruling of the lower court demanding that the originals be produced before admitting the triplicates complies with the established evidentiary rules, notably Section 46, Rule 123 of the Rules of Court.
Whether the evidence produced by carbon copying, based on its nature as a duplicate original, has full probative value equal to that of the original.