FACTS:

Petitioner Lara's Gifts and Decors, Inc. (LGDI) leased buildings/warehouses from J.Y. & Sons Realty Co., Inc. LGDI's properties were insured against fire and other risks with respondent PNB General Insurers Co., Inc. and respondent UCPB General Insurance Co., Inc. A fire broke out and damaged the leased buildings before the expiration of the insurance policy. LGDI filed a claim with the respondents, but it was denied due to insufficient supporting documents. LGDI then filed a Complaint for Specific Performance and Damages against respondents before the Regional Trial Court (RTC) of Makati City. During the proceedings, the parties made admissions and proposed stipulations of facts and issues, and numerous documentary exhibits were identified and pre-marked. Witnesses were presented, including a witness who testified on the reconstitution of commercial documents after the fire.

In a related matter, Mr. Villafuerte, the former president of LGDI, testified as a witness. Respondents sought to strike a supplemental affidavit and attached documents presented by petitioner, claiming it violated the Judicial Affidavit Rule and Guidelines on Pre-Trial. The RTC initially allowed the introduction of the documents, but later reversed its decision. Respondents filed a petition for certiorari before the Court of Appeals (CA), which initially dismissed the petition but later reversed its decision. The CA ruled that the introduction of the supplemental affidavit and attached documents violated the JA Rule. The petitioner argues that the introduction of additional evidence during re-direct examination is not absolutely prohibited, while the respondents insist on the mandatory nature of the provisions in the JA Rule and other procedural rules. The issue before the Supreme Court is whether the CA correctly invalidated the RTC's decision to allow the introduction of additional evidence and testimony.

ISSUES:

1. The sole issue for the resolution of the Court is whether or not the CA erred in disallowing the introduction of additional documentary exhibits during trial and the filing of the 2nd Supplemental Judicial Affidavit of Mrs. Villafuerte.

2. Whether the trial court has the discretion to allow the introduction of additional evidence during trial.

3. Whether the trial court properly exercised its discretion in allowing the introduction of the Questioned Documents during the redirect examination.

4. Whether Mr. Villafuerte, as a witness, is competent to testify on the Questioned Documents.

5. Whether the private documents introduced as evidence by the petitioner were properly authenticated.

6. Whether the 2nd Supplemental Judicial Affidavit filed by the petitioner during trial was admissible.

7. Whether the trial court gravely abused its discretion in allowing the presentation of the questioned documents in court.

8. Whether the trial court erred in admitting the 2nd Supplemental Judicial Affidavit of petitioner's witness.

RULING:

1. The Court finds merit in the petition. The CA did not err in allowing the introduction of additional documentary exhibits during trial and the filing of the 2nd Supplemental Judicial Affidavit of Mrs. Villafuerte.

2. Yes. The trial court has the discretion to allow the introduction of additional evidence during trial, provided there are valid grounds.

3. Yes. The trial court properly exercised its discretion in allowing the introduction of the Questioned Documents during the redirect examination because they were being presented in response to questions raised during the cross-examination.

4. The issue of Mr. Villafuerte's competence as a witness to testify on the Questioned Documents is separate and distinct from the issue of the propriety of presenting the documents. Disallowing the presentation of the documents on the ground of Mr. Villafuerte's incompetence is premature at this stage.

5. The private documents introduced as evidence by the petitioner were not properly authenticated. Under Section 20 of the Rules on Evidence, before any private document is received in evidence, its due execution and authenticity must be proved. The failure to properly authenticate the documents would result in their inadmissibility.

6. The 2nd Supplemental Judicial Affidavit filed by the petitioner during trial was admissible. While the belated submission of evidence is subject to several conditions, the court ruled that the affidavit was properly admitted. The court noted that both parties reserved the right to present additional evidence, which waived the application of certain rules on the admissibility of evidence. The respondents also did not object to the introduction of the affidavit during the hearing and even manifested that they would not be objecting to the introduction of the documents.

7. The trial court did not gravely abuse its discretion in allowing the presentation of the questioned documents in court.

8. The trial court did not err in admitting the 2nd Supplemental Judicial Affidavit of petitioner's witness.

PRINCIPLES:

• In an action for certiorari, the court's task is to determine whether the court a quo acted with grave abuse of discretion amounting to excess or lack of jurisdiction.

• Grave abuse of discretion means such capricious and whimsical exercise of judgment as is equivalent to lack of jurisdiction. The abuse of discretion must be patent and gross.

• The jurisdiction of the court is narrow in scope as it is limited to resolving only errors of jurisdiction.

• The Judicial Affidavit Rule (JA Rule) supplements and augments existing procedural rules and did not intend to supplant or amend them.

• The submission of additional evidence during trial is not absolutely proscribed by the JA Rule and the Guidelines on Pre-Trial.

• Parties are mandated to file and serve the judicial affidavits and documentary or object evidence of their witnesses before pre-trial or preliminary conference, but this does not prohibit the submission of additional evidence during trial.

• The purpose of the JA Rule and the Guidelines on Pre-Trial is to expedite court proceedings, ensure prompt disposition of cases, and decongest court dockets.

• Failure to timely submit judicial affidavits and exhibits as required by the Judicial Affidavit Rule (JA Rule) shall be deemed a waiver of their submission, subject to certain conditions.

• The court has the discretion to allow the introduction of additional evidence during trial, other than those identified and pre-marked during the pre-trial, provided there are valid grounds.

• The witness may be re-examined by the party calling him or her on redirect examination to explain or supplement his or her answers given during cross-examination, subject to the discretion of the court.

• The competence of a witness to testify on a particular object or documentary evidence and the propriety of presenting such evidence are separate and distinct issues.

• Private documents must be properly authenticated before they can be received in evidence.

• The belated submission of evidence is subject to conditions and may be admitted if there is a valid reason or good cause.

• Parties are bound by the contents of the Pre-Trial Order unless they seek to amend it.

• The admissibility of additional evidence during trial is dependent on its relevance to the issues raised and the necessity for its introduction.

• Litigants are strictly enjoined to adhere to the provisions of the Judicial Affidavit Rule and to be circumspect in the contents of court documents and pleadings.