People of the Philippines vs. Cristina M.
Hernandez
General Rule: Courts are not authorized to take judicial notice of the contents of the
records of other cases, even when such cases have been tried or are pending in the
same court.
Exception: A court may properly treat all or any part of the original record of a case
filed in its archives as read into the records of a case pending before it, when with the
knowledge of the opposing party, reference is made to it, by name and number or in
some other manner by which it is sufficiently designated.
Republic of the Philippines v. Hon. Court of Appeals and Josefa Gacot (G.R. No.
119288, August 18, 1997)
The Court cited the principle that courts can take judicial notice of their own acts and
records in the same case.
The Court reasoned that while the 1950 decision was not formally offered as
evidence during the rehearing, it was a matter of record in the same case and should
have been judicially noticed by the Court of Appeals.
Marcelo Steel Corporation v. Court of Appeals (G.R. No. L-35851, October 8, 1974)
The Court held that the Court of Appeals could take judicial notice of the respondents'
admission in the previous certiorari case, as it was a matter of public record and had
already been judicially admitted.
The Court emphasized that the purpose of the rule requiring a statement about the
appeal bond in the record on appeal is to avoid disputes about the timeliness of the
appeal. However, when a matter is already judicially admitted, there is no need for
further proof or dispute.
The Court stated that it would be absurd to require the parties to litigate the same
issue again when it had already been settled in a previous case.
The Court concluded that the Court of Appeals did not abuse its discretion in refusing
to dismiss the appeal, as it acted in accordance with law and the principle of judicial
notice.
Expertravel & Tours, Inc. v. Court of Appeals (G.R. No. 152392, May 26, 2005)
The Court emphasized that judicial notice is limited to matters of common knowledge
or those easily verifiable from sources of unquestionable accuracy.
The Court found that the existence of the teleconference and the resolution was not a
matter of common knowledge and was not easily verifiable.
State Prosecutors v. Judge Manuel T. Muro (A.M. No. RTJ-92-876, September 19, 1994)
The Court emphasized that judicial notice is discretionary and should be exercised
with caution, limited to matters of common knowledge or easily verifiable from reliable
sources.
The Court found that the President's announcement and the repeal of the Central
Bank Circular were not matters of common knowledge and were not easily verifiable
from reliable sources.
Republic of the Philippines v. Science Park of the Philippines, Inc. (G.R. No. 237714,
November 12, 2018)
Judicial Notice: The Supreme Court upheld the MCTC's decision to take judicial
notice of DAO 97-37. It was determined that the conditions for the exception to
the general rule against taking judicial notice of other case records were met.
The Government Prosecutor involved did not object to the stipulation in the prior
case and accepted the certified copy of DAO 97-37.
Doctrine of Judicial Notice: The case underscores the importance of the
doctrine of judicial notice, which allows courts to recognize certain facts without
the need for formal proof. The court can take judicial notice of facts that are
commonly known or can be accurately and readily verified, as in the case of
DAO 97-37.
