14.

Patula vs People (c) Public records, kept in the Philippines, of private documents required by law to be entered
GR NO. 164457 therein.
April 11, 2012 All other writings are private.
By: Pax - The nature of documents as either public or private determines how the documents may be
presented as evidence in court.
Topic: Authentication and Proof of Documents - A public document, by virtue of its official or sovereign character, or because it has been
Petitioners: Anna Patula acknowledged before a notary public is self-authenticating and requires no further
Respondents: People authentication in order to be presented as evidence in court.
- In contrast, a private document is any other writing, deed, or instrument executed by a
FACTS: private person without the intervention of a notary or other person legally authorized by
- Petitioner was charged with estafa under an information filed in the RTC. Petitioner, a which some disposition or agreement is proved or set forth.
saleswoman, allegedly failed to deliver the Php 131k she got from customers of the company - The requirement of authentication of a private document is excused only in four instances,
she works from. specifically:
- The prosecution presented 2 witnesses. Go and Guivencan. (a) when the document is an ancient one within the context of Section 21, Rule 132 of the
- During the direct examination of Guivencan, the Prosecution marked the ledgers of Rules of Court;
petitioner’s various customers allegedly with discrepancies as Exhibits B to YY and their (b) when the genuineness and authenticity of an actionable document have not been
derivatives, inclusive. specifically denied under oath by the adverse party;
- In the course of Guivencan Direct-examination,petitioner’s counsel interposed a continuing (c) when the genuineness and authenticity of the document have been admitted; or
objection on the ground that the figures entered in Exhibits B to YY and their derivatives, (d) when the document is not being offered as genuine.
inclusive, were hearsay because the persons who had made the entries were not themselves - There is no question that Exhibits B to YY and their derivatives were private documents
presented in court. because private individuals executed or generated them for private or business purposes or
- With that, petitioner’s counsel did not anymore cross-examine Guivencan, apparently uses. Considering that none of the exhibits came under any of the four exceptions, they could
regarding her testimony to be irrelevant because she thereby tended to prove falsification, not be presented and admitted as evidence against petitioner without the Prosecution
an offense not alleged in the information. dutifully seeing to their authentication in the manner provided in Section 20 of Rule 132 of
- The Prosecution then formally offered its documentary exhibits, including Exhibits B to Y the Rules of Court.
and their derivatives (like the originals and duplicates of the receipts supposedly executed - Section 20. Proof of private documents. – Before any private document offered as authentic
and issued by petitioner), inclusive, the confirmation sheets used by Guivencan in auditing is received in evidence, its due execution and authenticity must be proved either:
the accounts served by petitioner, and Guivencan’s so-called Summary (Final Report) of (a) By anyone who saw the document executed or written; or
Discrepancies. (b) By evidence of the genuineness of the signature or handwriting of the maker.
- After the Prosecution rested its case, the Defense decided not to file a demurrer to - Go’s attempt at authentication of the signature of petitioner on the receipt immediately
evidence although it had manifested the intention to do so, and instead rested its case. fizzled out after the Prosecution admitted that the document was a mere machine copy, not
- The RTC, stating that inasmuch as petitioner had opted "not to present evidence for her the original.
defense" the Prosecution's evidence remained "unrefuted and uncontroverted," rendered its - Guivencan’s identification of petitioner’s signature on two receipts based alone on the fact
decision finding petitioner guilty of estafa. that the signatures contained the legible family name of Patula was ineffectual, and exposed
yet another deep flaw infecting the documentary evidence against petitioner.
ISSUE: - Apparently, Guivencan could not honestly identify petitioner’s signature on the receipts
W/N the ledgers and receipts (Exhibits B to YY, and their derivatives, inclusive) were either because she lacked familiarity with such signature, or because she had not seen
admissible as evidence of petitioner’s guilt for estafa as charged despite their not being duly petitioner affix her signature on the receipts.
authenticated.

HELD/RATIO: NO
- Section 19, Rule 132 of the Rules of Court distinguishes between a public document and a
private document for the purpose of their presentation in evidence.
- Section 19. Classes of documents. – For the purpose of their presentation in evidence,
documents are either public or private.
Public documents are:
(a) The written official acts, or records of the official acts of the sovereign authority, official
bodies and tribunals, and public officers, whether of the Philippines, or of a foreign country;
(b) Documents acknowledged before a notary public except last wills and testaments, and