LETICIA KUMMER vs PEOPLEOF TH PHILIPPINES RULING:

GR NO. 174461 – SEPTEMBER 11, 2013 YES. Public documents are admissible in court without further proof of
their due execution and authenticity. The chemistry report shows
DOCTRINE: Public documents are admissible in court without further proof
positive result of paraffin test is a public document.
of their due execution and authenticity.
In other words, the forensic chemist does not need to be presented
as witness to identify and authenticate the chemistry report.
Furthermore, the entries in the chemistry report are prima facie
FACTS: evidence of the facts they state, that is, of the presence of gunpowder
residue on the left hand of Johan and on the right hand of the
 Jesus Mallo accompanied by Antonio Mallana went to the house of
petitioner. As a matter of fact, the petitioner herself admitted the
the Petitioner.
presence of gunpowder nitrates on her fingers, albeit ascribing their
 Petitioner then opened the door and shot Mallo who at first was presence from a match she allegedly lighted. Accordingly, we hold
able to ran away together with Mallana. that the chemistry report is admissible as evidence.
 However, petitioner was able to shot Mallo again which cause him
to eventually fall flat on the ground. It is also worthy to note that the credibility of the witnesses are not
 Following morning, policemen informed petitioner about the firing impugned by the slight variance on their testimonies and affidavit given.
in their house. Petitioner together with her son was accused of Slight contradictions are badges of credibility rather than indicia of bad
homicide. faith. It proves their testimonies have not been rehearsed. Further, no
person has perfect faculties of senses or recall.
 Petitioner used in her defense that they were already asleep during
that time. Therefore, the positive result of the paraffin test as corroborated by the
 RTC later on decided in favor of the prosecution based on testimonies of the witnesses is sufficient to convict Petitioners. No
testimonies of prosecution eyewitnesses who both positively reversible error was committed by the Court.
identified Petitioner as the person who shot Mallo.
 Testimonies given were coupled by the positive findings of
gunpowder nitrates on the left hand of Johan and Petitioner’s right
IWASANA VS PEOPLE
hand.
 Petitioner contends that testimonies given were not credible,
paraffin test results should not be considered in deciding the case.
 It further contends that prosecution failed to cite motive in killing
the victim.

ISSUE: Whether the positive result of the paraffin test was properly
admitted as evidence.