G.R. No. 175602 - People vs. Valdez

In 1994, Benson Industries, Inc. (BII) engaged Young Builders Corporation (YBC) to construct its commercial building at Escario St., Cebu City, purportedly on an accomplishment-billing basis.
As of May 18, 1998, YBC alleged completion of main contract works worth ₱54,022,551.39, of which ₱40,678,430.00 was paid, leaving ₱13,344,121.39. Extra works totaled ₱11,839,110.99, less ₱350,880.00, for a combined collectible of ₱24,832,352.38.

August 13, 1998: YBC filed a collection complaint in RTC–Cebu City (Civil Case No. CEB-22526). BII answered, denying the accomplishment-billing arrangement, alleging delays, defective work, lack of extra-work authorization, and claiming offsets.
BII filed a Demurrer to Evidence, denied on July 16, 2002; after trial, the RTC issued judgment on November 21, 2008 awarding YBC ₱24,832,352.38 plus legal interest, attorney’s fees (₱500,000.00) and litigation expenses (₱100,000.00).
BII appealed to the Court of Appeals (CA), challenging factual findings and documentary proof.
June 28, 2011: CA reversed and set aside the RTC decision, excluded YBC’s Accomplishment Billing (Exh. “B”) and related private documents for lack of authentication, and dismissed the complaint.
September 14, 2011: CA denied YBC’s Motion for Reconsideration. YBC filed a Rule 45 petition for review on certiorari before the Supreme Court.

Whether the CA erred in excluding YBC’s Accomplishment Billing (Exhibit “B”) for lack of probative value despite its later adoption by BII as Exhibit “2.”
Whether the CA erred in ruling that the letter from Ernesto Dacay, Sr. (Exhibit “F”) was not duly authenticated.
Whether the CA erred in reversing the RTC judgment on the grounds that:

The Accomplishment Billing had no probative value;
Exhibit “F” lacked authentication; and
The Certification of completion (Exhibit “E”) was contradicted by YBC’s own evidence.