View full case

RCBC BANKARD SERVICES CORPORATION v. MOISES ORACION

FACTS:

This case involves a petition for review on certiorari filed by petitioner RCBC Bankard Services Corporation (petitioner) assailing the decision and order of the Regional Trial Court (RTC) in Civil Case No. 73756. Respondents Moises Oracion, Jr. and Emily L. Oracion (respondents) applied for and were granted a credit card by petitioner. However, they failed to pay the total amount due under the credit card. Petitioner filed a complaint for sum of money before the MeTC, but the case was dismissed on the ground of lack of preponderance of evidence. Petitioner filed an appeal, but the RTC affirmed the MeTC decision. Hence, the petition for review before the Supreme Court.

ISSUES:

  1. Whether the petitioner can raise the argument that the attachments to its complaint are electronic documents under the Rules on Electronic Evidence, even though it did not raise this argument before the trial court.

  2. Whether the attachments to the complaint can be considered as electronic documents and admitted as evidence.

  3. Whether the annexes to the complaint, which are photocopies of the Statement of Accounts (SOAs) and the Credit History Inquiry, are admissible as electronic documents.

  4. Whether the annexes to the complaint can be given any probative value.

RULING:

  1. The petitioner cannot raise the argument that the attachments are electronic documents for the first time on appeal since it did not raise this argument before the trial court. Petitioner is precluded from raising new issues on appeal that were not raised before the lower courts.

  2. Even if the argument was properly raised, the attachments to the complaint cannot be considered as electronic documents and admitted as evidence. They did not pass the test of admissibility under the Rules on Electronic Evidence as they were not authenticated in the required manner. The petitioner failed to comply with the rules regarding authentication and could not establish the integrity and reliability of the supposed electronic documents.

  3. The annexes to the complaint are inadmissible as electronic documents because they were not properly authenticated by the custodian or other qualified witnesses, as required by Rule 8 of the Rules on Electronic Evidence.

  4. The annexes to the complaint are mere photocopies of the SOAs and the Credit History Inquiry and cannot be given any probative value as substitutionary documents under the Best Evidence Rule.

PRINCIPLES:

  • Parties cannot raise new issues on appeal that were not raised before the lower courts.

  • Electronic documents must pass the test of admissibility under the Rules on Electronic Evidence, including authentication, to be considered as evidence.

  • Affidavit of evidence is one method of proof for establishing the admissibility and evidentiary weight of an electronic document.

  • The Best Evidence Rule requires the presentation of the original document when the subject of inquiry is its contents.

  • Under the Rules on Electronic Evidence, an electronic document is regarded as the functional equivalent of an original document if it is a printout or output readable by sight or other means, shown to reflect the data accurately.

  • The authentication of electronic documents requires the testimony of the custodian or other qualified witness to establish that the document was made by electronic means and kept in the regular course of business.

  • Copies of a document are equally regarded as originals when they are made by electronic, optical, or similar means and accurately reflect the electronic data message or electronic document.