EVIDENCE CASE DIGEST

1. GOVERNMENT SERVICE INSURANCE SYSTEM vs. DINNAH VILLAVIZA

THE FACTS:

Petitioner Winston Garcia, as President and General Manager of the GSIS, filed
separate formal charges against respondent Dinnah Villaviza, for Grave Misconduct and/or
Conduct Prejudicial to the Best Interest of the Service pursuant to the Rules of Procedure in
Administrative Investigation (RPAI) of GSIS Employees and Officials.
On appeal, the Civil Service Commission (CSC) found the respondents guilty of the
lesser offense of Violation of Reasonable Office Rules and Regulations and reduced the
penalty to reprimand. The CSC ruled that respondents were not denied their right to due
process but there was no substantial evidence to hold them guilty of Conduct Prejudicial to
the Best Interest of the Service. Instead.

ISSUES:

WHETHER AN ADMINISTRATIVE TRIBUNAL MAY APPLY SUPPLETORILY THE

PROVISIONS OF THE RULES OF COURT.
RULING:

Yes. It is true that Section 4 of the Rules of Court provides that the rules can be
applied in a "suppletory character." Suppletory is defined as "supplying deficiencies." 10 It
means that the provisions in the Rules of Court will be made to apply only where there is an
insufficiency in the applicable rule. There is, however, no such deficiency as the rules of the
GSIS are explicit in case of failure to file the required answer. What is clearly stated there is
that GSIS may "render judgment as may be warranted by the facts and evidence submitted
by the prosecution."

2. THE PEOPLE OF THE PHILIPPINES vs.PABLITO ANDAN y HERNANDEZ @ BOBBY

G.R. No. 116437 March 3, 1997

THE FACTS:
Accused-appellant Pablito Andan y Hernandez alias "Bobby" was accused of the
crime of rape with homicide.
During the investigation, In the presence of the mayor, the police, representatives of
the media and appellant's own wife and son, appellant confessed his guilt. He disclosed how
he killed Marianne and volunteered to show them the place where he hid her bags. He asked
for forgiveness from Larin and Dizon whom he falsely implicated saying he did it because of
ill-feelings against them.

ISSUES:

WHETHER OR NOT THE CONFESSION OF THE APPELLANT IS ADMISSIBLE

EVIDENCE.
 RULING:

Yes. Under these circumstances, it cannot be successfully claimed that appellant's

confession before the mayor is inadmissible. It is true that
a municipal mayor has "operational supervision and control" over the local
police 32 and may arguably be deemed a law enforcement officer for purposes of applying
Section 12 (1) and (3) of Article III of the Constitution. However, appellant's confession to the
mayor was not made in response to any interrogation by the latter. 33 In fact, the mayor did
not question appellant at all. No police authority ordered appellant to talk to the mayor. It was
appellant himself who spontaneously, freely and voluntarily sought the mayor for a private
meeting. The mayor did not know that appellant was going to confess his guilt to him. When
appellant talked with the mayor as a confidant and not as a law enforcement officer, his
uncounselled confession to him did not violate his constitutional rights. 34 Thus, it has been
held that the constitutional procedures on custodial investigation do not apply to a
spontaneous statement, not elicited through questioning by the authorities, but given in an
ordinary manner whereby appellant orally admitted having committed the crime. 35 What the
Constitution bars is the compulsory disclosure of incriminating facts or confessions. The
rights under Section 12 are guaranteed to preclude the slightest use of coercion by the state
as would lead the accused to admit something false, not to prevent him from freely and
voluntarily telling the truth. 36 Hence, we hold that appellant's confession to the mayor was
correctly admitted by the trial court.
3. FRANCISCO vs. HOUSE OF REPRESENTATIVES
G.R. No. 160261, November 10, 2003

THE FACTS:

Impeachment proceedings were filed against Supreme Court Chief Justice Hilario G.
Davide. The justiciable controversy poised in front of the Court was the constitutionality of
the subsequent filing of a second complaint to controvert the rules of impeachment provided
for by law.
ISSUES:

Whether or Not the filing of the second impeachment complaint against Chief Justice
Hilario G. Davide, Jr. with the House of Representatives falls within the one year bar
provided in the Constitution
RULING:

Yes, the second impeachment complaint against Chief Justice Hilario G. Davide, Jr
is barred under paragraph 5, section 3 of Article XI of the Constitution.
Having concluded that the initiation takes place by the act of filing and referral or
endorsement of the impeachment complaint to the House Committee on Justice or, by the
filing by at least one-third of the members of the House of Representatives with the
Secretary General of the House, the meaning of Section 3 (5) of Article XI becomes clear.
Once an impeachment complaint has been initiated, another impeachment complaint may
not be filed against the same official within a one-year period.
4. PEOPLE OF THE PHILIPPINES vs. ANTONIO LAUGA
G.R. No. 186228 March 15, 2010

FACTS:
The appellant was accused of the crime of qualified rape. Moises Banting a “bantay
bayan” found the appellant in his house. He invited appellant to the police station to which
appeallant obliged. At the outpost, he admitted to him that he raped AAA because he was
unable to control himself.

ISSUE:
WHETHER OR NOT THE CONFESSION OF THE APPELLANT WITH THE
BANTAY BAYAN IS ADMISSIBLE EVIDENCE.

RULING:

The Supreme Court ruled that the extrajudicial confession of appellant, which was
taken without counsel, in admissible evidence. The Barangay Tanods, including the
Barangay Chairman may be deemed as law enforcement officer for the purposes of applying
Article III, Section 12(1) and (3) of the Constitution. Thus, without the ruling on the legality of
the actions taken by Moises Boy Banting, and the specific scope of duties and
responsibilities delated to a “bantay bayan” particularly on the authority to conduct custodial
investigation, any inquiry he makes has the color of the state-related functions and objective
insofar as the entitlement of a suspect to his constitutional rights provided for under Article
III, Section 12 of the Constitution, otherwise known as Miranda rights is concerned.

5. DATALIFT MOVERS, INC. vs. BELGRAVIA REALTY & DEVELOPMENT CORPORATION

G.R. No. 144268 August 30, 2006

FACTS:

The premises involved in this case is a warehouse (bodega) used by petitioner

Datalift Movers, Inc. (Datalift for short) for its cargoes in connection with its brokerage
business. After the one-year contract period expired, lessee Datalift continued in possession
and enjoyment of the leased warehouse, evidently by acquiesance of lessor Belgravia or by
verbal understanding of the parties After the one year contract period expired, lessee Datalift
continued in possession and enjoyment of the leased warehouse, evidently by acquiesance
of lessor Belgravia or by verbal understanding of the parties.

ISSUE:

WHETHER OR NOT THE LESSOR OR THE TENANT DENY THE OWNERSHIP OF

HIS LESSEE OR THE OWNER.

RULING:

No. The Rules of Court already sufficiently shields respondent Belgravia, as lessor,
from being questioned by the petitioners as lessees, regarding its title or better right of
possession as lessor because having admitted the existence of a lessor-lessee relationship,
 the petitioners are barred from assailing Belgravia's title of better right of possession as their
lessor.

Section 2, Rule 131, of the Rules of Court provides:

SEC. 2. Conclusive presumptions. -- The following are instances of conclusive

presumptions:

(a) Whenever a party has, by his own declaration, act, or omission, intentionally and
deliberately led another to believe a particular thing true, and to act upon such belief, he
cannot, in any litigation arising out of such declaration, act or omission, be permitted to falsify
it;

(b) The tenant is not permitted to deny the title of his landlord at the time of the
commencement of the relation of landlord and tenant between them. (Underscoring
ours.)

Conclusive presumptions have been defined as "inferences which the law makes so
peremptory that it will not allow them to be overturned by any contrary proof however
strong." 7 As long as the lessor-lessee relationship between the petitioners and Belgravia
exists as in this case, the former, as lessees, cannot by any proof, however strong, overturn
the conclusive presumption that Belgravia has valid title to or better right of possession to the
subject leased premises than they have.

6. PEOPLE OF THE PHILIPPINES vs. JOHNNY M. QUIZON

G. R. no. 142532 November 18,2003

FACTS:

Appellant Johnny M. Quizon found guilty beyond reasonable doubt of the crime Robbery with
homicide. No direct evidence was present by the prosecution to establish the guilt of the accused.
His conviction was based on circumstantial evidence introduced by the prosecution. The
circumstantial evidence presented are the testimonies of the witnesses that saw Johnny who left the
office during the time when the crime was probably committed.

ISSUE:

WHETHER OR NOT THE COURT ERRED IN FINDING THE ACCUSED-APPELLANT

GUILTY OF ROBBERY BASED ON CIRCUMSTANTIAL EVIDENCE.

RULING:

Yes. Well-settled is the rule that a person may be conviction on the basis of circumstantial
evidence, but the prove circumstances should exonerably lead to one fair and reasonable conclusion
pointing to the accussed as the guilty person, to the exclusion of the others. In the instant case,
there is no testimony as to the death of the victim but only general medico-legal explanation that the
strangulation of the victim heart and lung disease. There is no evidence of fingerprints, hair and skin
samples on the deceased that might lead to the identity of the killer.
As the saying goes: The sea of suspicion has no shore, and the court that embarks upon it is without
rudder or compass. No court when confronted with issues that affect the life and liberty of citizens in
free society, should treat flippantly the latter’s constitutional guarantees and supply deficiencies in
the evidence for the prosecution with its own bias, suspicion or speculation.

The Supreme Court reversed and set aside accused-appellant Johny M. Quizon be
acquitted.

7. PEOPLE OF THE PHILIPPINES vs. RUBEN BARON

G.R. No. 213215 January 11, 2016

FACTS:

accused-appellant Ruben Baron (Baron) was charged with the rape and killing of a seven-
year-old girl identified as AAA. Eight (8) witnesses testified for the prosecution: AAA’s mother,
Alcid Flores, Arsenio Valguna, Barangay Captain Segundina Morales, Ma. Concepcion
Tacorda,2 Gennivive Belarma, Dr. Tito D. Doromal, and rebuttal witness Romeo Inocencio.

In light of the facts obtaining and the jurisprudence aforecited, judgment is hereby rendered
finding the accused Ruben Baron GUILTY beyond reasonable doubt of the crime of RAPE WITH
HOMICIDE hereby sentencing the said accused to the supreme penalty of DEATH via lethal
injection.

ISSUE:

WHETHER OR NOT THE APPELLANT MAY BE CONVICTED OF THE OFFENSE

CHARGED BASED ON CIRCUMSTANTIAL EVIDENCE.

RULINGS:

The requirements for circumstantial evidence to sustain a conviction are settled. Rule 133,
Section 4 of the Revised Rules on Evidence provides:

Section 4. Circumstantial evidence, when sufficient. — Circumstantial evidence is sufficient for

conviction if:

(a) There is more than one circumstances;

(b) The facts from which the inferences are derived are proven; and

(c) The combination of all the circumstances is such as to produce a conviction beyond
reasonable doubt.26

Moreover, "factual findings of the trial court and its evaluation of the credibility of witnesses and their
testimonies are entitled to great respect and will not be disturbed on appeal, unless the trial court is
shown to have overlooked, misapprehended, or misapplied any fact or circumstance of weight and
substance."27

A careful examination of the records shows that there is nothing that warrants a reversal of the
Decisions of the Regional Trial Court and of the Court of Appeals.
 As pointed out by the Court of Appeals, a multiplicity of circumstances, which were attested to by
credible witnesses and duly established from the evidence, points to no other conclusion than
that accused-appellant was responsible for the rape and killing of the seven-year-old child.

8. MILAGROS MANONGSONG vs. FELOMENA JUMAQUIO ESTIMO

G. R. No. 136773 June 25, 2003

FACTS:

Milagros and Carlito Manongsong ("petitioners") filed a Complaint 6 on 19 June 1992,

alleging that Manongsong and respondents are the owners pro indiviso of the Property.
Invoking Article 494 of the Civil Code,7 petitioners prayed for the partition and award to them
of an area equivalent to one-fifth (1/5) of the Property or its prevailing market value, and for
damages. The Jumaquio sisters presented a notarized KASULATAN SA BILIHAN NG LUPA.
Plaintiff Milagros Manongsong debunks the evidence as fake. The document of sale, in the
observance of the Court, is however duly authenticated by means of a certificate issued by
the RTC of the Manila Clerk of Court as duly notarized public document. No countervailing
proof was adduced by plaintiffs to overcome or impugn the document’s legality or its validity.

ISSUE:

WHETHER OR NOT THE SPOUSES MANONGSONG HAVE THE BURDEN OF

PROOF TO DISPUTE THE VALIDTY OF THE KASULATAN SA BILIHAN NG LUPA.

RULING:

Yes. The Supreme Court simply put, he who alleges the affirmative of the issue has
the burden of proof, and upon the plaintiff in a civil case, the burden of proof never parts.
However, in the course of trial in a civil case, once plaintiff makes out a prima facie case in
his favor, the duty or the burden of evidence shifts to defendant to controvert plaintiff's prima
facie case, otherwise, a verdict must be returned in favor of plaintiff. Moreover, in civil cases,
the party having the burden of proof must produce a preponderance of evidence thereon,
with plaintiff having to rely on the strength of his own evidence and not upon the weakness of
the defendant’s. The concept of "preponderance of evidence" refers to evidence which is of
greater weight, or more convincing, that which is offered in opposition to it; at bottom, it
means probability of truth.

9. PHILIPPINE TRUST COMPANY vs. REDENTOR R. GABINETE

G.R. No. 216120 March 29, 2017

FACTS:

Petitioner Philtrust, a domestic commercial banking corporation duly organized and

existing under Philippine laws, filed a complaint on March 8, 2006 against Shangrila Realty
Corporation, a domestic corporation duly organized under Philippine laws, together with Elisa
Tan and respondent Redentor Gabinete alleging that petitioner granted Shangrila's
application for a renewal of its bills discounting line in the amount of Twenty Million Pesos
(₱20,000,000.00) as shown by a letter-advice dated May 28, 1997 bearing the conformity of
Shangrila's duly-authorized representatives, Tan and respondent Gabinete.
 ISSUE:

WHETHER OR NOT THE RESPONDENT HAS THE BURDEN OF PROOF TO

PROVE THAT HIS SIGNATURE IS FORGERY

RULING:

Yes. s a rule, forgery cannot be presumed and must be proved by clear, positive and
convincing evidence, the burden of proof lies on the party alleging forgery. 26 One who alleges
forgery has the burden to establish his case by a preponderance of evidence, or evidence which is
of greater weight or more convincing than that which is offered in opposition to it. 27 In this case, the
respondent was not able to prove the fact that his signature was forged.

It is also worthy to note that the document being contested has been notarized and thus, is
considered a public document. It has the presumption of regularity in its favor and to contradict all
these, evidence must be clear, convincing, and more than merely preponderant.

10. SUSAN A. YAP vs ELIZABETH LAGTAPON

G.R. No. 196347 January 23, 2017

FACTS:

Respondent Lagtapon instituted a civil suit against [petitioner Yap] for a sum of money with
the Regional Trial Court of Negros Occidental. Petitioner Yap wholly denied the fact of service of
Summons, as reflected in the Return of Service dated November 4, 1997 14 accomplished by the
RTC's process server, Roy R. Precioso.

ISSUE:

WHETHER OR NOT THE PETITIONER HAS THE BURDEN OF PROOF TO PROVE THAT
THE SUMMON WAS INVALIDLY SERVED.

RULING:

Yes. In this case, the burden of proof to discharge such presumption lay with petitioner Yap. t
is axiomatic that a public official enjoys the presumption of regularity in the discharge of one's official
duties and functions. 48 Here, in the absence of clear indicia of partiality or malice, the service of
Summons on petitioner Yap is perforce deemed regular and valid. Correspondingly, the Return of
Service of Precioso as process server of the RTC constitutes prima facie evidence of the facts set
out therein. To successfully overcome such presumption of regularity, case law demands that the
evidence against it must be clear and convincing; absent the requisite quantum of proof to the
contrary, the presumption stands deserving of faith and credit.