People of the Philippines v. Noel Enojas, et al., G.R. No. 204894, 10 March 2014

Remedial Law; Evidence; Electronic Evidence; Admissibility; Text Messages – As to the admissibility of the text messages, the RTC admitted them in conformity with the Court’s earlier Resolution applying the Rules on Electronic Evidence to criminal actions. Text messages are to be proved
by the testimony of a person who was a party to the same or has personal knowledge of them.16 Here, PO3 Cambi, posing as the accused Enojas, exchanged text messages with the other accused in order to identify and entrap them. As the recipient of those messages sent from and to the mobile phone in his possession, PO3 Cambi had personal knowledge of such messages and was competent to testify on them.

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