Sison v. People – G.R. Nos. 108280-83 November 16, 1995

Facts:
Accused were loyalist of the removed President Marcos. After the dispersal for their rally, they angrily mauled a suspected supporter of the newly installed President Aquino. The mauling was witnessed by Ranulfo Sumilang and Renato Banculo. The said mauling was also photographed by various newspapers. Subsequently the victim deceased. The accused then were arrested. The RTC rendered judgement against the accused. The RTC gave evidentiary weight on the photographs which corroborate the testimony of the witnesses. The accused appeal the cases contending that the RTC erred in giving evidentiary weigh in the photographs. The CA denied the appeal of the accused, hence this case.

Issue:
Whether the photographs can be used as credible evidence.

Held:
The rule in this jurisdiction is that photographs, when presented in evidence, must be identified by the photographer as to its production and testified as to the circumstances under which they were produced. The value of this kind of evidence lies in its being a correct representation or reproduction of the original, and its admissibility is determined by its accuracy in portraying the scene at the time of the crime. The photographer, however, is not the only witness who can identify the pictures he has taken. The correctness of the photograph as a faithful representation of the object portrayed can be proved prima facie, either by the testimony of the person who made it or by other competent witnesses, after which the court can admit it subject to impeachment as to its accuracy. Photographs, therefore, can be identified by the photographer or by any other competent witness who can testify to its exactness and accuracy.