G.R. No. 34098 , September 17, 1930
ORIENT INSURANCE COMPANY, petitioner, vs. E. P. REVILLA, Judge of First Instance of Manila, and TEAL MOTOR CO., INC., respondents.

FACTS

The Teal Motor Co., Inc. (plaintiff in the lower court) filed a civil action against Orient Insurance Company to recover on fire insurance policies. The insurance company raised the defense that the suit was filed beyond the three-month period stipulated in the policies after the claim was rejected. In its replication, Teal Motor Co. alleged that the delay was due to a request by the insurance company’s representative to defer legal action for possible compromise. During trial, Teal Motor Co.’s president, E. M. Bachrach, testified that he received a letter from his attorneys (Guevara, Francisco & Recto) dated July 13, 1929, urging him to file the cases. When asked to produce the letter, Bachrach agreed to show only the part about urging the filing, but refused to disclose other portions, claiming they contained privileged attorney-client communications regarding fees and retainer agreements. The trial judge (respondent Judge Revilla) sustained the objection and allowed only the quoted portion to be read into the record, denying Orient Insurance Company’s attorney the right to examine the entire letter. Orient Insurance Company then filed this original petition for certiorari and mandamus to compel the judge to permit inspection of the full letter.

ISSUE

Whether the trial judge erred in refusing to allow the adverse party’s attorney to examine the entire letter, part of which was used by the witness during testimony, on the ground that the undisclosed portions were protected by attorney-client privilege.

RULING

Yes. The Supreme Court granted the writ of mandamus, directing the respondent judge to permit the petitioner’s attorney to inspect the entire letter (Exhibits 49 and 49-A). The Court held that when a part of a document is presented in evidence by a witness, the adverse party is entitled to inspect the whole document to determine its context and relevance. The claim of attorney-client privilege was untenable because the letter, as described, contained matters related to the case (the urging to file suit) and other distinct matters (fee arrangements). The Court emphasized that the right to inspect is essential for cross-examination and to ensure a fair trial. The petitioner had no other adequate remedy, as the document was not part of the record for appeal purposes, making mandamus appropriate to correct the trial court’s error.