Object (Real) Evidence under Rule 130: Categories of Object Evidence

Under Rule 130 of the Rules of Evidence in the Philippines, object (real) evidence refers to tangible items presented in court for examination as evidence. The essence of object evidence is that it is evidence that can be inspected by the senses (seen, touched, smelled, etc.) and does not require verbal explanation to establish its existence, identity, or characteristics. Object evidence is divided into several categories, which are outlined and discussed below.

A. Classification of Object Evidence

Direct Evidence
- These are objects directly involved in the incident or controversy being litigated. They are the actual objects that are the subject of examination or dispute.
- Examples:
  - The murder weapon (e.g., a gun or knife).
  - A forged document in a forgery case.
  - Drugs in a prosecution for drug trafficking.
Demonstrative Evidence
- These are objects that illustrate, demonstrate, or clarify the facts of a case but are not directly involved in the incident. They are representations rather than the actual evidence.
- Examples:
  - Models, maps, sketches, diagrams, or photographs.
  - Videos or animations reconstructing an event.
  - Charts or graphs summarizing data.
Representative Evidence
- These are objects that serve as samples or specimens of larger quantities, tested to infer properties of the whole.
- Examples:
  - A blood sample taken from the accused or victim.
  - A soil or water sample from a crime scene.
  - A representative portion of counterfeit money in a case involving large-scale counterfeiting.
Explanatory Evidence
- These are objects used to explain or illustrate testimony or facts in a case, without necessarily being primary evidence.
- Examples:
  - A prosthetic limb to illustrate an injury.
  - Tools or equipment used in the commission of a crime (e.g., a crowbar or rope).

B. Rules Governing Object Evidence

Relevance
- Object evidence must be relevant to the issue at hand. It should help establish or disprove a fact that is material to the case.
Authentication (Section 21, Rule 132)
- Object evidence must be authenticated, meaning it must be proven that the object is what it purports to be.
- Methods of authentication:
  - Testimony of a witness who has knowledge of the object.
  - Evidence of chain of custody, particularly in drug-related cases or sensitive objects.
Integrity
- The condition of the object must not have materially changed from the time of the incident to the time it is presented in court. Alteration, contamination, or substitution may render the object inadmissible.
Identification
- The object must be clearly identified as the actual object involved in the case.
- Identification can be made through:
  - Witness testimony.
  - Unique markings or features of the object (e.g., serial numbers, distinctive traits).
Exclusionary Rules
- Object evidence may be excluded if:
  - Its probative value is substantially outweighed by the danger of unfair prejudice.
  - It is immaterial or irrelevant to the case.
  - It was obtained in violation of constitutional rights (e.g., due process, unreasonable searches and seizures under the Bill of Rights).

C. Examples of Object Evidence in Philippine Jurisprudence

Physical Evidence in Criminal Cases
- People v. Dacuma (G.R. No. 188900, August 30, 2010): The Supreme Court emphasized that the unbroken chain of custody in handling the physical evidence (in this case, drugs) is essential for its admissibility.
- People v. Pagaduan (G.R. No. 205725, March 23, 2015): The murder weapon was admitted as real evidence after the prosecution sufficiently identified and linked it to the crime.
Documentary Evidence as Object Evidence
- Heirs of Velasquez v. Court of Appeals (G.R. No. 153007, June 3, 2004): A forged deed of sale was presented as object evidence to prove fraudulent transfer of property.
Demonstrative Evidence in Civil Cases
- Republic v. Sandiganbayan (G.R. No. 152154, July 15, 2003): Photographs and diagrams were used as demonstrative evidence to establish the location and structure of buildings in a land dispute.

D. Legal Principles Governing Specific Categories of Object Evidence

Weapons
- Must be identified by witnesses and linked to the crime.
- The chain of custody is critical to ensure the integrity of the weapon.
Documents as Real Evidence
- Physical characteristics of the document (e.g., paper type, ink, handwriting, or signature) may be examined.
- Authentication is required unless the document falls under exceptions (e.g., public documents, ancient documents).
Digital Evidence
- Digital evidence, such as video recordings, photographs, or computer-generated data, can be considered object evidence.
- Rule on Cybercrime Evidence: Digital evidence must be authenticated by proving the integrity of the storage device and ensuring the original data has not been altered.
Biological Evidence
- Blood, hair, saliva, and other biological samples require laboratory analysis and certification.
- Chain of custody must show that the sample was preserved and unaltered.

E. Presentation of Object Evidence in Court

Marking and Identification
- All object evidence must be marked and identified before it is formally offered in evidence. Markings are typically done during pre-trial.
Inspection by the Court
- The court may inspect the object evidence to ascertain its nature, appearance, and relevance.
Examination by Experts
- Expert witnesses may be called to examine and explain the significance of object evidence (e.g., forensic examiners, chemists, or handwriting analysts).
Offer of Evidence
- Object evidence must be formally offered by the party presenting it. The opposing party may object to its admissibility on legal grounds.

F. Limitations on Object Evidence

Practical Impossibility
- When presenting the object in court is impractical or impossible (e.g., a building, large machinery, or extensive land), representations such as photographs or models may be admitted instead.
Privacy Concerns
- In cases involving sensitive or obscene materials (e.g., child pornography), special procedures may be employed to protect the privacy of the individuals involved.
Dangerous Objects
- Dangerous objects (e.g., explosives, biohazardous materials) may require alternative forms of evidence, such as photographs or videos, to avoid safety risks.

Summary

Object (real) evidence plays a critical role in the judicial process as it provides tangible proof of facts in dispute. Proper identification, authentication, and preservation of object evidence are essential for its admissibility. Philippine jurisprudence emphasizes the importance of the chain of custody, relevance, and integrity of real evidence. The Rules of Evidence under Rule 130 provide a framework for determining the admissibility of object evidence, ensuring that it is presented and evaluated in a manner consistent with the constitutional rights of all parties involved.