Case Digest (G.R. No. 271360)
Facts:
Grace M. Trimillos v. FCash Global Lending, Inc., G.R. No. 271360, August 13, 2025, Supreme Court Third Division, Inting, J., writing for the Court.Petitioner Grace M. Trimillos filed a complaint on July 26, 2019 with the National Privacy Commission (NPC) against respondent FCash Global Lending, Inc. (operator of the "Fast Cash" app) alleging violations of Republic Act No. 10173 (Data Privacy Act of 2012). Trimillos claimed FCash accessed her phone contacts without authorization and sent text messages to those contacts falsely identifying them as her guarantors, thereby besmirching her reputation. She submitted screenshots of the messages and related email correspondence to the National Telecommunications Commission as supporting evidence.
The NPC set a Discovery Conference; the evidence Trimillos submitted on September 13, 2019, was made available for examination. FCash did not participate in the initial conference and later failed to file a responsive comment despite an order directing it to do so. The parties attempted mediation but could not agree and proceedings resumed. With no responsive pleadings from FCash, the investigating officer submitted the matter for resolution.
In a Decision dated November 5, 2020, the NPC awarded Trimillos nominal damages of ₱15,000 and forwarded the record to the Department of Justice recommending prosecution of FCash under Sections 28 and 31 of the DPA. The NPC found that FCash processed personal information in excess of necessity and disclosed it maliciously. FCash’s motion for reconsideration was denied by NPC Resolution dated March 11, 2021.
FCash then filed a Petition for Review with the Court of Appeals (CA). In a Decision dated May 17, 2023, the CA reversed and set aside the NPC’s ruling and dismissed the case, holding that the screenshots of the text messages were inadmissible because Trimillos failed to authenticate them under the Rules on Electronic Evidence. The CA denied reconsideration in a Resolution dated December 11, 2023.
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Issues:
- Did respondent FCash waive its objection to the admissibility of the electronic evidence by failing to raise it at the appropriate time before the NPC?
- If not waived, did the Court of Appeals correctly reverse the NPC’s decision on the ground that the electronic evidence was inadmissible for lack of authentication under the Rul...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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