GR 198998; (June, 2019) (Digest)
G.R. No. 198998 June 19, 2019
Young Builders Corporation vs. Benson Industries, Inc.
FACTS
Petitioner Young Builders Corporation (YBC) filed a collection case against respondent Benson Industries, Inc. (BII) for the unpaid balance of construction work and extra works on BII’s commercial building, totaling Php24,832,352.38. YBC claimed the construction was on an accomplishment billing basis. BII countered that the agreement was based on a fixed timetable and contract price, and that YBC was in default due to delay, abandonment, and substandard work. The Regional Trial Court (RTC) ruled in favor of YBC, ordering BII to pay the claimed amount with interest and attorney’s fees.
The Court of Appeals (CA) reversed the RTC’s decision and dismissed the complaint. The CA found that YBC’s sole evidence to prove its monetary claim was an Accomplishment Billing (Exhibit “B”), a private document. The CA ruled that YBC failed to authenticate this document by not presenting the person who prepared it or any witness who could testify to its due execution and genuineness, as required by the Rules of Court. Consequently, the CA excluded Exhibit “B” from evidence.
ISSUE
Whether the Court of Appeals erred in excluding YBC’s Accomplishment Billing for lack of authentication, thereby dismissing the collection suit.
RULING
The Supreme Court denied the petition and affirmed the CA’s ruling. The core legal principle is that a private document requires authentication before it can be received in evidence as proof of its due execution and genuineness. Under Section 20, Rule 132 of the Rules of Court, a private document must be authenticated either by the person who executed it, by a witness to its execution, or by evidence of the genuineness of the signature or handwriting of the maker.
YBC failed to comply with this rule. Its lone witness, Arch. Nelson Go Yu, was not the preparer of the Accomplishment Billing and could not testify to its authenticity. YBC did not present the document’s author or any other competent witness for this purpose. Without proper authentication, the document is not admissible as evidence. Since the Accomplishment Billing was the sole basis for YBC’s monetary claim, its exclusion was fatal to YBC’s cause of action. The burden of proof lies with the plaintiff to establish its case by preponderance of evidence. By failing to present competent evidence to substantiate its claim for payment, YBC did not discharge this burden. Therefore, the CA correctly dismissed the complaint.