De Guzman vs. Court of Appeals

A photocopy of a lost original document is admissible as secondary evidence to prove its contents, provided the due execution of the original and the fact of its loss are duly proven. A party's bare denial, unsubstantiated by clear and convincing evidence, is a negative and self-serving declaration that cannot prevail over the credible testimony of witnesses asserting affirmative matters.

Petitioner Celestina De Guzman and private respondent Lucila De Guzman-Sioson were sisters-in-law. Private respondents alleged that petitioner, as manager of a riceland they co-owned, failed to deliver Lucila's share of the harvest. After a demand for 1,500 cavans of palay, private respondents received a letter (Exhibit C) purportedly from petitioner offering to settle the matter for P92,000. Following negotiations and petitioner's subsequent failure to pay, private respondents filed a collection suit.

• Nature of the Action: Private respondents (spouses Cresenciano and Lucila De Guzman-Sioson) filed a complaint for collection of a sum of money (P92,000) against petitioner Celestina De Guzman.
• The Alleged Debt and Letter: Private respondents claimed petitioner owed them P92,000 as settlement for undelivered shares from a riceland harvest. They presented a photocopy of a letter (Exhibit C) purportedly sent by petitioner, which stated: "Ang handa ko lang bayaran sa inyo ay P92,000 at sa ano man oras na kunin ninyo ay ibibigay ko."
• Petitioner's Defense: Petitioner denied being indebted, denied managing the riceland, and claimed the letter was a forgery. She asserted she never confronted private respondents about the letter.
• Delay in Filing Suit: Private respondents explained the two-year delay in filing the case was due to ongoing negotiations for an amicable settlement, which the law encourages.
• Loss of Original Letter: Private respondent Cresenciano testified that the original letter was lost after he left it at a photocopying service within the Cabanatuan City Hall premises during a hearing for a related estafa case. Despite efforts, the original could not be located.
• Credibility Finding: The trial court and the Court of Appeals found petitioner's testimony unworthy of credence. During cross-examination, she denied her signatures on several documents, only to acknowledge them on redirect examination, indicating a predisposition to deny all allegations.

• Credibility of Testimony: Petitioner argued the lower court erred in giving credence to private respondents' testimony regarding the letter (Exhibit C) and the acknowledgment of the P92,000 debt.
• Admissibility of Photocopy: Petitioner contended the court erred in believing the loss of the original of Exhibit C and, consequently, in admitting the photocopy as evidence.
• Malicious Prosecution: Petitioner maintained the case was malicious and vindictive, and that damages should have been awarded to her instead of to private respondents.

• Validity of the Debt: Respondents countered that petitioner's letter (Exhibit C) constituted a clear acknowledgment of her obligation to pay P92,000.
• Sufficiency of Secondary Evidence: Respondents argued that the due execution of the letter and the proven loss of the original justified the admission of the photocopy as secondary evidence under the Rules of Court.
• Petitioner's Lack of Credibility: Respondents asserted that petitioner's blanket denials, especially in light of her contradictory testimony regarding her own signatures, rendered her defense implausible.

• Admissibility of Evidence: Whether the photocopy of the letter (Exhibit C) was admissible as secondary evidence to prove the existence and contents of the lost original.
• Sufficiency of Defense: Whether petitioner's bare denial was sufficient to overcome the affirmative evidence presented by private respondents.

• Admissibility of Evidence: The photocopy was properly admitted. The due execution of the original letter was proven through a comparison of handwriting with petitioner's admitted signatures. The loss of the original was also sufficiently established through credible testimony. Under Rule 130, Section 4 of the Revised Rules of Court, when the original is lost, its contents may be proved by a copy, provided its execution and loss are proven.
• Sufficiency of Defense: Petitioner's defense of denial failed. Unsubstantiated denial is negative, self-serving evidence with no weight in law and cannot prevail over the positive testimony of credible witnesses on affirmative matters. The lower courts' factual findings, affirmed by the Court of Appeals, are binding on the Supreme Court.

• Best Evidence Rule (Secondary Evidence Exception) — The rule requires the original document to be presented when its content is the subject of inquiry. An exception exists when the original is shown to be lost, destroyed, or unavailable without bad faith on the part of the offeror. To invoke this exception, the proponent must prove: (1) the due execution of the original, and (2) its subsequent loss, destruction, or unavailability. The Court applied this doctrine, holding that the photocopy's admission was proper because private respondents proved both the letter's authenticity (through signature comparison) and its loss (through Cresenciano's testimony).
• Weight of Denial as Evidence — A bare denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving declaration that has no probative weight and cannot be given greater evidentiary value than the testimony of credible witnesses who testify on affirmative matters. The Court relied on this principle to discredit petitioner's defense.

• "Denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence which has no weight in law and cannot be given greater evidentiary value over the testimony of credible witnesses who testified on affirmative matters." — This passage succinctly states the evidentiary weakness of an unsupported denial, a principle frequently cited in Philippine jurisprudence.
• "It is settled that if the original writing has been lost or destroyed or cannot be produced in court, upon proof of its execution and loss or destruction, or unavailability, its contents may be proved by a copy or a recital of its contents in some authentic document, or by recollection of witness." — This excerpt directly states the exception to the Best Evidence Rule applied in the case.

• Gobonseng, Jr. v. Court of Appeals, 246 SCRA 472 (1995) — Cited for the principle that the Supreme Court's jurisdiction is generally limited to reviewing errors of law, not re-evaluating evidence.
• Meneses v. Court of Appeals, 246 SCRA 162 (1995) — Cited for the rule that factual findings of the trial court, when affirmed by the Court of Appeals, are binding on the Supreme Court.
• Abadilla v. Tabiliran, Jr., 249 SCRA 447 (1995) — Cited as the source for the doctrine that an unsubstantiated denial is self-serving and has no weight in law.
• People v. Goce, 247 SCRA 780 (1995) — Cited to support the rule on the admissibility of secondary evidence when the original is lost.

• Rule 130, Section 4, Revised Rules of Court (Best Evidence Rule) — This provision states the general rule requiring the original document and enumerates the exceptions, including when the original is lost or destroyed. The Court applied this exception to admit the photocopy of the letter.

Justice Regalado, Justice Romero, Justice Puno, and Justice Torres, Jr.