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DRA. ABDULIA RODRIGUEZ v. CA

FACTS:

The petitioners filed a complaint against the private respondents for damages resulting from a fire that damaged their apartment buildings. The trial court dismissed the complaint for failure to prove that the fire was caused by the defendants' negligence. The Court of Appeals affirmed the trial court's decision, but deleted the damages awarded to the defendants.

The petitioners appealed to the Supreme Court, arguing that the Court of Appeals misapplied certain facts and should have admitted the fire investigation report as evidence. They also claimed that Section 44, Rule 130 of the Rules of Court should apply.

The petitioners wanted the Supreme Court to give full credit to the testimony of their witness, Noel Villarin, who they deemed to be truthful and reliable. However, the trial court did not believe Villarin due to his alleged ulterior motive. The trial court also found inconsistencies between Villarin's testimony and the testimony of the defendants' witnesses.

After considering the arguments presented, the Supreme Court accepted the petition for review.

ISSUES:

  1. Whether the trial court erred in not believing the testimonies of the plaintiffs' principal witness.

  2. Whether the Fire Investigation Report should have been admitted in evidence as an exception to the hearsay rule.

  3. Whether the Fire Investigation Report (Exhibits "A," "A-1" to "A-4" inclusive) should be admitted as evidence despite the objection of hearsay

  4. Whether the statements included in the report qualify as "official information" under Section 44 of Rule 130

  5. Whether the doctrine of res ipsa loquitur can be applied in this case.

  6. Whether the Report of Major Enriquez can be admitted as an exception to the hearsay rule.

RULING:

  1. The trial court did not err in not believing the testimonies of the plaintiffs' principal witness. The trial court found that the defendants' witnesses contradicted the testimony of the principal witness and that the principal witness displayed a propensity for needlessly detailed observation. The trial court, being in a better position to decide the credibility of the witnesses, found the testimony of the principal witness to be less weighty and a piece of evidence that taxes belief. The Supreme Court will not interfere with the judgment of the trial court in passing on the credibility of witnesses unless there are facts or circumstances of weight and influence which have been overlooked, and the petitioners failed to present any convincing arguments to refute the observations and findings of the trial court.

  2. The Fire Investigation Report should not have been admitted in evidence as an exception to the hearsay rule. The Court applied the requisites set forth in Africa v. Caltex (Phil.) Inc. for the admissibility of entries in official records. The third requisite requires that the person who gave the statements recorded in the report must have personal knowledge of the facts stated and the duty to give such statements for the record. In this case, the reporting officer who prepared the Fire Investigation Report did not have personal knowledge of what actually took place, and the information he received did not qualify as "official information" since those who gave the statements had no personal knowledge of the facts stated and no duty to give such statements for the record.

  3. The trial court erred in rejecting the Fire Investigation Report as hearsay. Since the officer who signed the report, Major Enriquez, testified in open court and was available for cross-examination, the portions of the report that were based on his personal knowledge or perceptions were not hearsay. The other parts of the report, such as the summary of statements, may be considered as independently relevant statements gathered during the investigation and may be admitted as such, but not necessarily to prove their truth.

  4. The statements included in the report qualify as "official information" under Section 44 of Rule 130. When Major Enriquez testified on his report and made himself available for cross-examination, it effectively removed the report from the hearsay rule. The entries in the official record become admissible as prima facie evidence of the facts stated. Section 44 recognizes the necessity and trustworthiness of official statements, giving a presumption that public officers discharge their duties with accuracy and fidelity.

  5. The doctrine of res ipsa loquitur cannot be applied in this case. The trial court concluded that the fire was not caused by an instrumentality within the exclusive control of the defendants, a requisite for the application of the doctrine. The doctrine of res ipsa loquitur is not intended to dispense with the requirement of proof of culpable negligence, but merely determines and regulates what shall be prima facie evidence thereof.

  6. The Report of Major Enriquez cannot be admitted as an exception to the hearsay rule. The officer's conclusions and recommendations in the report do not provide direct evidence and are considered hearsay.

PRINCIPLES:

  • The trial judge is in a better position to decide the credibility of witnesses since he personally heard the witnesses and observed their deportment and manner of testifying.

  • The Supreme Court will not interfere with the judgment of the trial court in passing on the credibility of witnesses unless there are facts or circumstances of weight and influence which have been overlooked.

  • Entries in official records made by a public officer or a person specially enjoined by law are prima facie evidence of the facts stated therein.

  • For statements acquired by a public officer to qualify as "official information," the persons who gave the statements must have personal knowledge of the facts stated and the duty to give such statements for the record.

  • Entries in an official record may be admitted as an exception to the hearsay rule if the officer who made the record testifies in court and makes themselves available for cross-examination.

  • Statements made by public officials in discharge of their official duties may be given in evidence and taken to be true under a certain degree of caution.

  • The law confers a particular confidence in public officers, presuming that they will fulfill their duties accurately and faithfully.

  • The doctrine of res ipsa loquitur determines and regulates what shall be prima facie evidence of culpable negligence, but does not dispense with the requirement of proof.

  • Hearsay evidence, including conclusions and recommendations in a report, is not admissible as an exception to the hearsay rule.