GR 223274; (June, 2019) (Digest)
G.R. No. 223274 June 19, 2019
RCBC BANKARD SERVICES CORPORATION, Petitioner vs. MOISES ORACION, JR. AND EMILY L. ORACION, Respondents
FACTS
Respondents obtained a credit card from petitioner RCBC Bankard. They subsequently incurred unpaid charges totaling ₱117,157.98. Petitioner filed a Complaint for Sum of Money before the Metropolitan Trial Court (MeTC). Attached to the complaint were purported “duplicate original” copies of the Statements of Account (SOAs) and a Credit History Inquiry. These documents bore a stamp mark stating “DUPLICATE ORIGINAL” and included a printed, non-manual signature of a bank manager. The respondents failed to file an answer, prompting the MeTC to render judgment based on the pleadings.
The MeTC dismissed the complaint for petitioner’s failure to establish its case by preponderance of evidence. It ruled that the attached documents were inadmissible under the Best Evidence Rule, being mere photocopies or stamp marks, not originals. The Regional Trial Court (RTC) affirmed the dismissal on appeal, holding that the stamped “duplicate originals” were not the original documents contemplated by the Rules of Court, as they contained no original signatures.
ISSUE
Whether the MeTC and the RTC correctly dismissed the complaint based on the inadmissibility of the attached “duplicate original” documents under the Best Evidence Rule.
RULING
Yes, the dismissal was proper. The Supreme Court affirmed the lower courts’ rulings. The core legal principle applied is the Best Evidence Rule under Section 3, Rule 130 of the Rules of Court, which requires the production of the original document when its contents are the subject of inquiry. The documents petitioner attached to its complaint—the SOAs and Credit History Inquiry stamped “DUPLICATE ORIGINAL” with a printed signature—were not originals. They were mere reproductions created by a mechanical process (printing/stamping). The Court clarified that for electronic evidence, which these computer-generated records are, the original is the printout or output readable by sight, shown to reflect the data accurately. However, the attached documents were not simple printouts but were further marked with a stamp declaring them as “duplicate originals,” indicating they were not the primary records. Petitioner failed to present the original electronic data or explain the loss of the original writing to justify secondary evidence. Consequently, without admissible evidence to prove the indebtedness, petitioner failed to meet the burden of proof by preponderance of evidence. The Court also found the petition frivolous and imposed treble costs on petitioner’s counsel for pursuing a meritless appeal grounded on a deficient complaint.