08/07/2026
The (SC) has ruled that a duplicate or photocopy of original documents, whether in paper or electronic form, can be admitted as evidence in court, provided there is no genuine question regarding the originalโs authenticity or fairness in using the copy.
In a Decision written by Chief Justice Alexander G. Gesmundo, the SCโs First Division upheld the conviction of Ybo Lastimosa (Lastimosa) for the murder of Ildefonso Vega, Jr. (Vega) in a case involving the use of a photocopy of Vegaโs death certificate as key evidence.
Witnesses testified during trial that Lastimosa shot Vega in the head outside a cockpit in Cebu City. Vegaโs wife also testified that Vega was already dead when she found him at the hospital. To support her testimony, the prosecution presented a photocopy of Vegaโs death certificate, which confirmed that he died from gunshot wounds.
Convicted by the trial court of homicide and by the Court of Appeals of murder, Lastimosa argued before the SC that the prosecution failed to prove that the crime was committed because the original death certificate was not presented. He claimed that a photocopy, without comparison to the original for authentication, should not have been admitted as evidence.
The SC affirmed the Court of Appeals, sentencing Lastimoso to reclusion perpetua and ordered him to pay PHP 275,000 in civil indemnity and damages. It explained that under Rule 130, Section 4(c) of the 2019 ๐๐ฆ๐ท๐ช๐ด๐ฆ๐ฅ ๐๐ถ๐ญ๐ฆ๐ด ๐ฐ๐ฏ ๐๐ท๐ช๐ฅ๐ฆ๐ฏ๐ค๐ฆ, a duplicate is admissible as the original unless there is a genuine question about the originalโs authenticity or it would be unfair to use the duplicate.
This rule applies to both paper-based and electronic documents, reflecting the modern reality where duplicates are often as reliable as originals.
However, the SC emphasized that while a photocopy may be admissible, its weight or value depends on how well it corroborates or supports other available evidence.
In this case, the photocopy of the death certificate, combined with the testimonies of Vegaโs wife and other eyewitnesses, sufficiently established that Vega died from gunshot wounds and that Lastimosa was responsible.
Read the full text of the Press Release at
https://tinyurl.com/36r9m76u.
Read the full text of the Decision at https://tinyurl.com/mwe35fhe.
Copying of this content is subject to the SC PIOโs Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.
