Tuesday, February 18, 2014

PHILIPPINE AIRLINES, INC., petitioner, vs. JAIME M. RAMOS, NILDA RAMOS

G.R. No. 92740 March 23, 1992
PHILIPPINE AIRLINES, INC., petitioner,
vs.
JAIME M. RAMOS, NILDA RAMOS, ERLINDA ILANO, MILAGROS ILANO, DANIEL ILANO AND FELIPA JAVALERA, respondents.

FACTS

Plaintiffs complained that they were not allowed to board their PAL( Philippines Air Lines) flight, despite the fact that they went to the check-in counter one hour before departure. They alleged that when they arrived there no one was at the counter. They testified that the PAL clerk arrived 30 minutes before departure. PAL however, presented as evidence the plaintiffs’ tickets with notation “late 4:04” and the passenger manifest which showed that two other passengers who arrived earlier than plaintiffs, were not accommodated.
ISSUE
Are the documents presented by PAL admissible? Which should prevail the oral testimony of plaintiffs or the documentary evidence presented by PAL?

HELD 

Yes. The documentary evidence presented by PAL to corroborate the testimonies of its witnesses are entries made in the regular course of business which plaintiffs failed to overcome with substantial and convincing evidence other than their testimonies. Consequently they carry more weight and credit. A writing or document made contemporaneously with a transaction which are evidence of facts pertinent to an issue, when admitted as proof of those facts, is ordinarily regarded as more reliable proof and of greater probative force than the oral testimony of a witness as to such fact based upon memory and recollection. Spoken words could be notoriously unreliable as against a written document that speaks a uniform language.

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