Case Summary (G.R. No. L-11944)
Factual Background and Dispute
CSFL and TKI entered into a business agreement whereby TKI imported children’s shoes manufactured by CSFL. Payment was structured so that TKI paid 30% via letters of credit and the remaining 70% by telegraphic transfer thirty days after delivery. Initially, TKI fulfilled its payment obligations but started defaulting in 2004. Despite many concessions by CSFL, unpaid accounts grew to over US$325,000 by mid-2005, excluding additional unpaid shipment worth $92,000. CSFL repeatedly demanded payment both verbally and in writing without success. Consequently, CSFL filed a lawsuit before the RTC for collection of sum of money and damages.
Trial Proceedings and Evidentiary Issues
During trial, CSFL presented sales invoices and order slips as evidence through its witness and officer, Ms. Susan Chiu. TKI objected to these being mere photocopies, challenging their admissibility. TKI also opposed evidence relating to attorney’s fees on the basis that it was not raised during pre-trial. The RTC admitted the exhibits on May 13, 2011, ruling they were part of the witness’s testimony despite TKI’s objections. TKI filed a motion for reconsideration, which the RTC denied on June 23, 2011, holding that the invoices were duplicate originals sufficiently established by testimony, and that attorney’s fees were implicitly part of the issues.
Petition to the Court of Appeals and the CA’s Ruling
TKI elevated the matter via a petition for certiorari with a prayer for injunctive relief before the CA, reiterating its objections to the admission of photocopied invoices and evidence on attorney’s fees. The CA affirmed the RTC’s orders with modification, excluding certain exhibits identified as mere photocopies on the ground that CSFL failed to present original invoices or prove applicable exceptions under Section 3, Rule 130 of the Rules of Court. However, the CA upheld the admission of evidence relating to attorney’s fees. CSFL’s motion for partial reconsideration was denied by the CA on January 16, 2012.
Issues Presented to the Supreme Court
Whether the Court of Appeals erred in excluding exhibits on the ground they were photocopies and not admitting duplicate originals as evidence, and whether the CA exceeded its jurisdiction in reviewing the RTC’s factual findings.
Legal Framework on Documentary Evidence
Under the Rules of Court, Rule 130:
- Section 3 mandates that the original document must be produced subject to specific exceptions (loss, custody by opponent, voluminous records, or public records).
- Section 4(b) provides that when two or more copies of a document are executed simultaneously with identical contents, all such copies are regarded as originals (duplicate originals).
- Section 5 allows proof of contents by copies if the original is unavailable without bad faith.
Supreme Court’s Analysis and Findings
Upon thorough examination of the records and stenographic notes, the Supreme Court found that the documents in question were properly shown to be duplicate originals, not mere photocopies. This was substantiated by the uncontradicted testimony of Ms. Susan Chiu, who explained that two copies of each invoice were created simultaneously—one for the customer and one retained by CSFL. Her testimony was firm, consistent, and unrebutted, establishing the credibility and authenticity of the duplicates under Section 4(b), Rule 130.
The Court emphasized that the CA erred by disregarding the evidence and accepting TKI’s bare assertion that the documents were mere photocopies, without giving due weight to the witness’s testimony and the trial court’s findings. Furthermore, the originals or duplicate originals were produced and compared during trial as required by the Rules of Evidence. The rejection of such evidence by the CA constituted improper re-evaluation of factual findings, beyond the limited scope of a certiorari proceeding which only addresses jurisdictional errors.
Procedural Considerations and Judicial Economy
The Court noted that CSFL’s suit had been pending for almost a decade, underscoring the need to resolve the matter on its merits promptly. It reminded TKI’s counsel of their duty not to unduly delay proceedings by resorting prematurely to extraordinary remedies rather than presenting their case in defense during trial. The RTC had already ruled that even if some exhibits were inadmissible, sufficient evidence remained to justify judgment, thus TKI had the opportunity to
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Case Syllabus (G.R. No. L-11944)
Facts of the Case
- In 2000, Capital Shoes Factory Ltd. (CSFL), a foreign corporation manufacturing and trading children's shoes, entered into an agreement with Traveler Kids, Inc. (TKI), a domestic shoe manufacturer and distributor.
- Under their agreement, TKI would import shoes made by CSFL’s China factory, with CSFL manufacturing goods per TKI’s special designs and specifications.
- Payment terms agreed upon: 30% of the purchase price via letters of credit, and the remaining 70% by telegraphic transfer, payable 30 days from delivery.
- For the first three years, TKI met its payment obligations; however, starting 2004, TKI began defaulting.
- CSFL granted concessions and extensions, and TKI made partial payments, but by July 10, 2005, unpaid accounts totaled US$325,451.39 plus accruing interest.
- Additionally, CSFL manufactured $92,000 worth of children’s shoes for TKI based on purchase orders.
- CSFL sent both verbal and written demand letters for payment which were ignored.
- To protect its interest, CSFL filed a complaint for collection of sum of money and damages against TKI before the Regional Trial Court (RTC), Branch 170, Malabon City.
Trial Proceedings and Evidentiary Issues
- During trial, CSFL’s witness identified several sales invoices and order slips as evidence of transactions with TKI.
- TKI objected, arguing the documents were mere photocopies, thus inadmissible.
- TKI also objected to evidence offered to prove attorney’s fees, contending that such matter was not raised during pre-trial.
- The RTC admitted the exhibits offered by CSFL despite TKI’s objections via the May 13, 2011 Order.
- After TKI's motion for reconsideration was denied on June 23, 2011, the RTC held that:
- The duplicate originals were sufficiently established by CSFL’s principal witness, Ms. Susan Chiu.
- The claim for attorney’s fees was impliedly included in the issues and thus properly admitted.
- TKI filed a certiorari petition before the Court of Appeals (CA), reiterating objections.
- The RTC proceeded with the trial despite TKI’s refusal to present evidence due to the pending CA petition, considering TKI’s right waived.
Court of Appeals Decision and Resolution
- On October 5, 2011, the CA partially granted TKI’s petition, modifying the RTC orders by excluding certain duplicate originals (Exhibits aDa to aGG-1a and aHHa to aKK-1a) on the ground they were mere photocopies.
- The CA ruled that CSFL failed to present the original invoices as required under Section 5, Rule 130 of the Rules of Court.
- The