FACTS
Edmundo Jose T. Buencamino, then Municipal Mayor of San Miguel, Bulacan, was charged with two counts of violation of Section 3(e) of R.A. No. 3019. The first charge concerned the collection of ₱1,000.00 "pass way fees" from the delivery trucks of Rosemoor Mining and Development Corporation (RMDC). The second concerned the alleged order to apprehend and impound two RMDC delivery trucks for failure to pay the fees. The prosecution presented testimonial and documentary evidence to establish the charges.
Among the documentary evidence presented by the prosecution were photocopies of Kapasiyahan Blg. 504 of the Sangguniang Panlalawigan of Bulacan, the Second Indorsement from the Provincial Attorney's Office, a letter from the Secretary of the Sangguniang Panlalawigan, and the DILG Preliminary Report. Buencamino timely objected to these documents on the ground that they were inadmissible hearsay and were merely photocopies. The prosecution nevertheless relied upon them to establish that the municipal resolution authorizing the fees had already been disapproved and that Buencamino therefore acted in evident bad faith.
For the second charge, the prosecution relied in part upon a Certificate of Blotter dated August 23, 2004 to establish that Buencamino had ordered the impounding of RMDC's trucks. The information recorded in the blotter had been reported by another person, while the police officer merely entered the report. Neither the person who allegedly made the report nor the officer who entered it was presented to testify regarding the truth of the information contained in the blotter.
The Sandiganbayan convicted Buencamino on both counts. It relied on the documentary and testimonial evidence in finding that he had acted with evident bad faith. Buencamino appealed to the Supreme Court, specifically challenging, among others, the admissibility and evidentiary value of the photocopied documents and the Certificate of Blotter.
ISSUE
The first issue was whether the photocopies of the documentary evidence offered by the prosecution were admissible when their contents were themselves offered to prove the truth of the matters stated therein.
The second issue was whether the Certificate of Blotter constituted sufficient evidence to establish that Buencamino ordered the apprehension and impounding of RMDC's trucks.
The third issue was whether, even assuming the documentary evidence were admissible, the totality of the evidence sufficiently established Buencamino's evident bad faith beyond reasonable doubt.
HELD
The Supreme Court GRANTED the petition and ACQUITTED Buencamino. The Court held that several documentary exhibits relied upon by the prosecution were inadmissible hearsay and failed to comply with the Best Evidence Rule. The challenged documents were photocopies, and the prosecution offered them precisely to prove the truth of their contents.
The Court explained that the Best Evidence Rule requires the original document to be produced when the contents of the document are the subject of inquiry, subject to the exceptions provided by the Rules of Evidence. Mere photocopies are therefore inadmissible when offered to prove the contents of the original and a timely objection has been made. Here, Buencamino had timely objected to each of the challenged documents.
The Court rejected the prosecution's argument that the documents were being used merely to establish an independent fact for which their contents were collateral. The Court found that the documents were offered specifically to establish the substance of their written contents—particularly that the municipal resolution had been disapproved and that Buencamino therefore knew that the collection of the fees had no legal basis. Thus, the documents went directly to the heart of the prosecution's allegation of evident bad faith.
The Court further held that evidence not objected to may be considered, including a mere photocopy when no objection is made when it is formally offered. However, that principle did not apply because Buencamino timely objected to the photocopies. Consequently, the challenged documents should have been excluded. The Sandiganbayan should have ruled on the objections immediately upon their offer instead of deferring the issue until the decision.
With respect to the Certificate of Blotter, the Supreme Court held that it was insufficient to establish that Buencamino ordered the impounding of the trucks. Entries in a police blotter, although made in the regular performance of official duties, are not conclusive proof of the truth of the matters stated therein because such entries may be incomplete or inaccurate. A certificate of blotter is only prima facie proof of the facts stated therein and should not be given undue significance or probative value. Without corroborating evidence, it could not sufficiently establish that Buencamino authored or ordered the impounding.
The Court also made an important distinction between admissibility and probative value. Admissibility determines whether evidence may be considered at all, while probative value concerns whether admitted evidence actually proves an issue. The Court found that the prosecution's documentary evidence failed on both levels: several documents were inadmissible, and even assuming their admissibility, the remaining evidence did not sufficiently prove evident bad faith.
The Court emphasized that in a criminal case, the prosecution must establish guilt beyond reasonable doubt. Since the prosecution failed to establish the element of evident bad faith with sufficient admissible and probative evidence, reasonable doubt remained. The constitutional presumption of innocence therefore required Buencamino's acquittal.
Finally, the Court expressly directed courts to rule on the admissibility of evidence immediately when it is offered and objected to, rather than postponing the ruling until the decision. It criticized the practice of admitting evidence "for whatever they are worth," emphasizing that inadmissible evidence cannot have probative value.
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