What is original of document?

a. An “original” of a document is the document itself or any counterpart intended to have the same effect by a person executing or issuing it. An “original” of a photograph includes the negative or any print therefrom. If data is stored in a computer or similar device, any printout or other output readable by sight or other means, shown to reflect the data accurately, is an “original.”

b. A “duplicate” is a counterpart produced by the same impression as the original, or from the same matrix, or by means of photography, including enlargements and miniatures, or by mechanical or electronic re-recording, or by chemical reproduction, or by other equivalent techniques which accurately reproduce the original.

c. A duplicate is admissible to the same extent as an original unless (1) a genuine question is raised as to the authenticity of the original, or (2) in the circumstances, it is unjust or inequitable to admit the duplicate in lieu of the original. (Section, 4 Rule 130).

As a general rule, in proving a case, a party must present the original document to the court. Exceptions to the general rule are the following:

a. When the original is lost or destroyed, or cannot be produced in court, without bad faith on the part of the offeror;

b. When the original is in the custody or under the control of the party against whom the evidence is offered, and the latter fails to produce it after reasonable notice, or the original cannot be obtained by local judicial processes or procedures;

c. When the original consists of numerous accounts or other documents which cannot be examined in court without great loss of time and the fact sought to be established from them is only the general result of the whole;

d. When the original is a public record in the custody of a public officer or is recorded in a public office; and

e. When the original is not closely-related to a controlling issue. (3a)

Well-settled is the rule that a receipt of payment is the best evidence of the fact of payment. A receipt is a written and signed acknowledgment that money or goods have been delivered (Cham vs. Paita-Moya, 556 SCRA 1).

When the original document is unavailable, has been lost or destroyed, or cannot be produced in court, the offeror upon proof of its execution or existence and the cause of its unavailability without bad faith on his part, may prove its contents by a copy, or by a recital of its contents in some authentic document, or by the testimony of witnesses in the order stated (Abadiano vs. Martir, 560 SCRA 676).

The Best Evidence Rule (now Original Document Rule) requires that the original document be produced whenever its contents are the subject of inquiry, (Tapayan v. Martinez, G.R. No. 207786, January 30, 2017, 816 SCRA 178, 189; cited in the case of Edmundo Jose T. Buencamino vs. People of the Philippines, G.R. Nos. 216745-46, November 10, 2020).

The “Best Evidence Rule” as encapsulated in Rule 130 of the Revised Rules [on Evidence] applies only when the content of such document is the subject of the inquiry (Gaw vs. Chua, 551 SCRA 505).