Capital Shoes Factory v. Traveler Kids
REITERATIONFacts
The Antecedents: Petitioner Capital Shoes Factory, Ltd. (CSFL), a foreign corporation, and respondent Traveller Kids, Inc. (TKI), a domestic corporation, entered into an agreement where TKI would import shoes and sandals manufactured by CSFL from its China factory. TKI agreed to pay 30% of the purchase price via letters of credit and the remaining 70% via telegraphic transfer within thirty days of delivery. While TKI initially complied for three years, it began defaulting in payments in 2004. Despite concessions and extensions granted by CSFL, TKI's unpaid accounts, as of July 10, 2005, amounted to U.S. $325,451.39, in addition to $92,000.00 worth of goods manufactured per TKI's specifications. CSFL's demands for payment were unsuccessful. Procedural History: CSFL filed a complaint for collection of sum of money and damages against TKI before the Regional Trial Court (RTC), Branch 170, Malabon City. During the trial, CSFL presented sales invoices and order slips as evidence, which TKI objected to as mere photocopies. TKI also objected to evidence presented for attorney's fees, arguing it was not a pre-trial issue. The RTC, in an Order dated May 13, 2011, admitted all of CSFL's exhibits. TKI moved for reconsideration, reiterating its objections, but the RTC denied it on June 23, 2011, stating that duplicate originals were sufficiently established and that attorney's fees were impliedly included in the claim. Instead of presenting its own evidence, TKI filed a petition for certiorari with the Court of Appeals (CA), challenging the RTC's orders. The CA, in a Decision dated October 5, 2011, affirmed the RTC's orders with modification, denying admission to certain exhibits (Exhibits "D" to "GG-1" and "HH" to "KK-1") on the ground that they were inadmissible photocopies. CSFL's motion for partial reconsideration was denied by the CA on January 16, 2012. The Petition: CSFL filed the present petition for review on certiorari under Rule 45 of the Rules of Court, arguing that the CA gravely erred in delving into the lower court's evaluation of evidence and factual findings, which is beyond the scope of a certiorari proceeding. CSFL contends that the excluded documents were admissible as they were duplicate originals, prepared simultaneously with their counterparts and retained by CSFL. TKI counters that CSFL's claim of duplicate originals was unsubstantiated. The Supreme Court found merit in CSFL's petition, ruling that the CA erred in excluding the documents. The Court held that Section 4(b) of Rule 130 of the Rules of Court allows duplicate originals, executed at the same time with identical contents, to be regarded as originals and admitted as evidence. The testimony of CSFL's witness, Ms. Susan Chiu, sufficiently established that the questioned exhibits were indeed duplicate originals, with one copy sent to the client and the other retained by CSFL. The Court reinstated the RTC's May 13, 2011 Order admitting all exhibits and remanded the case for further proceedings.
Issue(s)
Whether the Court of Appeals gravely erred in delving into the lower court's evaluation of evidence and factual findings in a certiorari proceeding. Whether the Court of Appeals correctly modified the RTC order admitting the exhibits offered by CSFL, specifically Exhibits "D" to "GG-1" and "HH" to "KK-1".
Ruling
The petition is granted. The Decision and Resolution of the Court of Appeals are reversed and set aside insofar as the exclusion of Exhibits "D" to "GG-1" and "HH" to "KK-1" are concerned. The May 13, 2011 Order of the RTC is reinstated. The records are remanded to the RTC for appropriate proceedings.
Ratio Decidendi
On the propriety of the certiorari proceeding: The Court reminds counsel for TKI of their duty as officers of the court to prevent undue impediment to the orderly administration of justice. Instead of presenting evidence after the RTC's order, TKI opted to file a petition for certiorari. The Court noted that even if the questioned exhibits were inadmissible, the RTC stated that there remained enough evidence to substantiate CSFL's claim. The Court reiterated the ruling in Johnson Lee v. People of the Philippines, stating that the RTC had jurisdiction over the cases, and the order admitting evidence, even if erroneous, was a mere error of judgment, not of jurisdiction. The admission of secondary evidence is a factual issue addressed to the sound discretion of the trial court, and unless grave abuse of discretion amounting to excess or lack of jurisdiction is shown, the resolution of the trial court must be sustained. The proper remedy for TKI, after the admission of evidence, was to adduce its own evidence and, if convicted, appeal the decision. Under Rule 45, only questions of law may be raised. On the admissibility of Exhibits "D" to "GG-1" and "HH" to "KK-1": The Court finds merit in the petition and holds that the CA erred in not admitting the invoices and order slips denominated as Exhibits "D" to "GG-1" and "HH" to "KK-1," which were duplicate originals. Section 4(b), Rule 130 of the Rules of Court provides that when a document is in two or more copies executed at or about the same time, with identical contents, all such copies are equally regarded as originals. The Court cited Trans-Pacific Industrial Supplies v. The Court of Appeals and Associated Bank and People vs. Tan to support the admissibility of duplicate originals. Records reveal that CSFL's principal witness, Ms. Susan Chiu, satisfactorily explained that these exhibits were duplicate originals, as CSFL usually prepared two sets of invoices for each transaction: one for the customer and one for their office, with the retained copies being presented in court. Her testimony was firm and consistent, indicating that the subject invoices were duplicate originals prepared at the same time. The Court found no reason why Section 4(b), Rule 130 should not apply, and these exhibits could be admitted as part of Chiu's testimony. Furthermore, the Court noted that the RTC records and TSNs showed that the duplicate originals were produced and compared with their photocopies during the hearing, and the photocopies were retained in the records, contrary to the CA's assertion.
Main Doctrine
Duplicate originals, prepared at or about the same time with identical contents, are equally regarded as originals and are admissible as evidence under Section 4(b), Rule 130 of the Rules of Court. A petition for certiorari is not the proper remedy to correct a mere error of judgment in the admission of evidence, absent a grave abuse of discretion amounting to excess or lack of jurisdiction.