Practice question
A document is fully identified in recorded testimony but never incorporated in the case record. Does that satisfy both Cesa requirements?
- Yes, identification alone necessarily is incorporation.
- Yes, counsel may keep the only copy privately forever.
- Yes, the court must reconstruct the document from memory.
- No.
- Yes, the second requirement has no independent meaning.
Legal references
- A.M. No. 19-08-15-SC, 2019 Amendments to the Revised Rules on Evidence, Rule 132, Sections 19-36 as specifically discussed: https://lawphil.net/courts/rules/am_19-08-15-sc_2019.html
- Spouses Cesa, substituted by heirs, v. Spouses Brucelas, et al., G.R. No. 255564, March 5, 2025, MAIN decision, qualified relaxation of formal offer and identification in recorded testimony: https://lawphil.net/judjuris/juri2025/mar2025/gr_255564_2025.html
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