W-Red Construction and Development Corporation v. Court of Appeals and Asia Industries, Inc.
REITERATIONFacts
The Antecedents: Petitioner W-Red Construction and Development Corporation (W-Red) purchased electrical equipment from respondent Asia Industries, Inc. (Asia Industries) between May 28, 1980, and May 23, 1981, for a total of P976,487.18. W-Red paid P701,877.93, leaving a balance of P298,183.05, inclusive of interest. Asia Industries filed a collection case against W-Red after the latter failed to settle its obligation despite demands. Procedural History: W-Red denied receipt of some items and alleged defective equipment. The Regional Trial Court (RTC) denied W-Red's demurrer to evidence. W-Red failed to appear at subsequent hearings, leading the RTC to declare its waiver of the right to present evidence. The RTC rendered judgment in favor of Asia Industries. The Court of Appeals (CA) affirmed the RTC's decision, and W-Red's motion for reconsideration was denied. The Petition: W-Red filed a petition for review, arguing that the CA and RTC committed grave abuse of discretion by admitting private documents (sales invoices and statement of account) that were not authenticated or identified. Specifically, W-Red contended that the sales invoices were mere photocopies and not authenticated, and the statement of account was not identified by its preparer.
Issue(s)
Whether the respondent Court of Appeals and the trial court committed a grave abuse of discretion when they admitted and considered private documents as evidence when said documents were not authenticated nor identified; specifically, whether the photocopies of the sales invoices were admissible as evidence. Whether the respondent Court of Appeals and the trial court committed a grave abuse of discretion when they admitted and considered private documents as evidence when said documents were not authenticated nor identified; specifically, whether the statement of account was admissible as evidence; and the weight of evidence and factual findings.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the judgment of the trial court. The petition for review was denied.
Ratio Decidendi
On the admissibility of photocopies of sales invoices: The Court found W-Red's claim that the sales invoices (Exhibits "A" to "R") were inadmissible for being mere photocopies to be untenable. The records showed that the originals of these documents were presented during the trial. This was clarified during the cross-examination of respondent's witness, where petitioner's counsel acknowledged the presentation of originals, and the court's practice confirmed that exhibits marked without the word "conditional" implied the presentation of originals. Therefore, it was not accurate to claim that the original exhibits were not presented before the trial court. On the admissibility of the statement of account and the weight of evidence and factual findings: The Court addressed W-Red's objection to the admissibility of the statement of account (Exhibit "S") on the ground of lack of authentication by its preparer. The Court, agreeing with the CA, found that respondent's sole witness, Alma Ramas, who was connected with the credit and collection department and monitored customer credit purchases, was competent to testify on petitioner's obligation. Her testimony was sufficient to establish the basis for the statement of account. The Court emphasized the distinction between admissibility of evidence and its probative value. It reiterated the well-established rule that factual findings of the trial court, when adopted and confirmed by the Court of Appeals, are binding and conclusive upon the Supreme Court, provided they are not manifestly erroneous or unsupported by the record. The Supreme Court is not a trier of facts, and its function is not to re-examine the weight of evidence. In this case, no cogent ground was found to disturb the conclusions of the CA and the RTC.
Main Doctrine
Photocopies of documents are admissible as evidence if the originals were presented during the trial, even if not explicitly stated as such in the marking of exhibits, especially when the opposing counsel was aware of the presentation of originals during cross-examination. Furthermore, factual findings of the trial court and the Court of Appeals, when not manifestly erroneous or unsupported by the record, deserve great respect and are binding on the Supreme Court.