G.R. No. 148825 - People vs. Canton

On December 2, 2010, respondents Moises Oracion, Jr. and Emily L. Oracion applied for and were granted a Bankard PESO Mastercard Platinum (Account No. 5243-0205-8171-4007) by petitioner RCBC Bankard Services Corporation.
Respondents used the card to purchase various items but failed to pay the total amount due of ₱117,157.98, inclusive of charges and penalties, or at least the minimum amount due.

Petitioner filed a Complaint for Sum of Money on February 7, 2012 before the Metropolitan Trial Court (MeTC), attaching what it labeled “duplicate original copies” of Statements of Account (SOAs) from April 17 to December 15, 2011 (Annexes “A”, “A-1” to “A-8”) and a Credit History Inquiry (Annex “B”). Each page bore a stamp “DUPLICATE ORIGINAL (Sgd.) CHARITO O. HAM, Senior Manager, Collection Support Division Head, Collection Group, Bankard Inc.”
Respondents received the SOAs and a demand letter dated January 26, 2012, but still did not settle their obligation. Summons was issued March 13, 2012, served by substituted service on April 11, 2012, and, upon respondents’ failure to answer, MeTC treated the case as submitted motu proprio under Section 6, Rule 9 of the 1991 Revised Rule on Summary Procedure.

MeTC Decision (September 28, 2012): Dismissed the complaint for lack of preponderance of evidence, ruling that the stamped SOAs and Credit History Inquiry were mere photocopies/substitutionary documents inadmissible under the Best Evidence Rule.
RTC Decision (August 13, 2013) and Order (March 1, 2016): Affirmed MeTC in toto, finding that petitioner failed to present originals or proper electronic‐evidence authentication; denied petitioner’s motion for reconsideration.

Whether the RTC erred in affirming the dismissal on the ground that petitioner’s “duplicate original copies” of SOAs and Credit History Inquiry were inadmissible, considering Section 1, Rule 4 of the Rules on Electronic Evidence, which treats electronic documents (print-outs) as originals under the Best Evidence Rule.
Whether, on the basis of substantial justice and equity, petitioner should be allowed to rectify its evidentiary deficiency by submitting additional or new electronic document print-outs.