Evidence Digest: THE PEOPLE OF THE PHILIPPINES VS. MODESTO CABUANG (1993)

Topic: Official Records (Rule 130, Section 44)

THE PEOPLE OF THE PHILIPPINES VS. MODESTO CABUANG, et al 
[217 SCRA 675 G.R. No. 103292 / January 27, 1993]

Facts:
The accused were found guilty of robbery with rape and homicide.They were convicted based on the medical report and primarily on the victim's cousin, Evelyn de Vera's sworn statement positively identifying the accused as among the perpetrators and which she later repeated in substantially identical terms before the trial court.

On appeal, the accused points to the entry in the police blotter which stated that the assailants were "still unidentified". It was likewise argued that Evelyn de Vera had never identified the appellants, who in fact had later identified the assailants from a police line-up.

Issue:
If the entries made in the police blotter are conclusive proofs of the truth of such entries.

Held:
NO. Entries in a police blotter, though regularly done in the course of performance of official duty are NOT conclusive proof of the truth of such entries. This Court held that entries in official records like a police blotter are only prima facie evidence of the facts therein set out, since the entries in the police blotter could be incomplete or inaccurate. Further, the testimony given in open court during the trial is commonly much more lengthy and detailed than the brief entries made in the police blotter. 

Thus, the trial court must necessarily consider all other evidence gathered in the course of the police investigation and presented in court, not merely relying on a police report.