G.R. No. 200065 , September 24, 2014.
CAPITAL SHOES FACTORY, LTD., Petitioner, vs. TRAVELER KIDS, INC., Respondent.

FACTS

Petitioner Capital Shoes Factory Ltd. (CSFL), a foreign corporation, and respondent Traveler Kids, Inc. (TKI), a domestic corporation, entered into an agreement wherein TKI would import shoes manufactured by CSFL. Their payment arrangement was 30% via letters of credit and 70% via telegraphic transfer 30 days from delivery. TKI defaulted on payments starting in 2004. As of July 10, 2005, TKI’s unpaid accounts amounted to U.S. $325,451.39, exclusive of interest, with an additional $92,000.00 worth of manufactured goods. Despite demands, TKI failed to pay, prompting CSFL to file a complaint for sum of money and damages.
During trial, CSFL presented sales invoices and order slips through its witness, Ms. Susan Chiu. TKI objected, arguing the documents were mere photocopies and that evidence for attorney’s fees was improperly offered as it was not a pre-trial issue. The Regional Trial Court (RTC) admitted all of CSFL’s exhibits. TKI filed a motion for reconsideration, which was denied. The RTC ruled that the documents were duplicate originals, as established by Chiu’s testimony, and that the claim for attorney’s fees was impliedly included in the issue of TKI’s liability.
TKI filed a petition for certiorari with the Court of Appeals (CA). The CA partially granted the petition, affirming the RTC’s orders but modifying them to exclude Exhibits “D” to “GG-1” and “HH” to “KK-1,” ruling they were inadmissible photocopies under the Rules of Court. CSFL filed a motion for partial reconsideration, which was denied, leading to this petition.

ISSUE

Whether the Court of Appeals correctly modified the RTC order by excluding the subject exhibits as inadmissible photocopies.

RULING

No. The Supreme Court granted the petition, finding that the excluded exhibits were duplicate originals, not mere photocopies, and were therefore admissible.
The Court applied Section 4(b), Rule 130 of the Rules of Court, which states that when a document is executed in two or more copies at or about the same time with identical contents, all such copies are regarded as originals. Citing Trans-Pacific Industrial Supplies v. Court of Appeals, the Court reiterated that duplicate originals are admissible as evidence.
The Court examined the transcripts and found that CSFL’s witness, Ms. Susan Chiu, consistently testified that for each transaction, two copies of invoices were prepared simultaneously: one sent to the customer and one retained by CSFL. The documents offered were the retained copies. Her testimony satisfactorily established that the exhibits were duplicate originals prepared at the same time as the originals. The Court found no indication they were mere photocopies. Therefore, the CA erred in excluding them under the best evidence rule. The RTC’s admission of the exhibits was correct.
The Supreme Court reversed the CA’s modification and reinstated the RTC’s orders admitting all of CSFL’s exhibits. The case was remanded to the RTC for appropriate proceedings.