De Guzman v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents, spouses Cresenciano and Lucila De Guzman, filed a complaint against petitioner Celestina De Guzman for collection of P92,000.00. They alleged that petitioner owed them this amount, presenting a letter (Exhibit C) purportedly written by petitioner acknowledging the debt and offering to pay P92,000.00. Petitioner was the widow of the private respondent Lucila's deceased brother, Andres De Guzman. Cresenciano claimed petitioner managed a riceland owned in common by Lucila and Andres, and that petitioner failed to deliver Lucila's share of the harvest. Cresenciano had previously demanded 1,500 cavans of palay from petitioner. Petitioner denied the allegations, claiming the letter was a forgery and that she was not the farm manager. Procedural History: The Regional Trial Court (RTC) of Cabanatuan City, Branch 29, ruled in favor of the private respondents, ordering petitioner to pay P92,000.00 with interest and P10,000.00 as attorney's fees. The Court of Appeals affirmed the RTC decision. The Petition: Petitioner filed a petition for review on certiorari with the Supreme Court, assigning errors related to the lower courts' credence to the testimony regarding Exhibit C, the belief in the loss of the original of Exhibit C, and the dismissal of her counterclaim for damages.
Issue(s)
Whether the lower courts erred in giving credence to the testimony that petitioner acknowledged the payment of P92,000.00 as shown in Exhibit "C", and whether the petitioner's testimony was credible. Whether the lower courts erred in believing the loss of the original of Exhibit "C" and admitting the photocopy as secondary evidence. Whether the lower courts erred in not dismissing the case, whether the case was malicious, and whether the lower courts erred in granting damages to the plaintiffs instead of the defendant.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of giving credence to the testimony regarding Exhibit "C" and the petitioner's credibility: The Supreme Court held that it is not its function to analyze and weigh evidence anew, especially when the factual findings of the trial court were affirmed by the Court of Appeals. The Court found petitioner's claims doubtful due to her tendency to deny practically all allegations, even retracting her denial of her own signatures on cross-examination. The appellate court aptly observed that petitioner seemed preconditioned to deny assertions, rendering her testimony unworthy of belief. The Court reiterated the rule that unsubstantiated denial is negative and self-serving evidence, lacking weight against credible testimony on affirmative matters. On the issue of believing the loss of the original of Exhibit "C" and admitting the photocopy: The Court found no error in admitting the photocopy (Exhibit C) as secondary evidence. The private respondent testified that the original was lost when he had it photocopied at the City Hall premises, and despite efforts, it could not be retrieved. The due execution of the document was proven by comparing petitioner's signature on the photocopy with her acknowledged signatures on other documents and her specimen signatures during trial. The Court cited the rule that if the original writing is lost, destroyed, or unavailable, its contents may be proven by a copy upon proof of its execution and loss. On the issue of dismissing the case, whether the case was malicious, and granting damages: The Court found no merit in the petitioner's claim that the case was malicious. The delay in filing the suit was attributed to ongoing settlement discussions between the parties, which the law encourages. The Court affirmed the lower courts' decision to award damages to the private respondents based on the established debt and the petitioner's failure to pay.
Main Doctrine
A photocopy of a document may be admitted as secondary evidence if the loss or unavailability of the original is duly proven, and its due execution is likewise established.