3. PEOPLE vs.

REANZARES By: Cal

334 S 624 Topic: Judicial Notice
June 29, 2000
Ponente: J. Bellosillo
DOCTRINE: An ordinary witness cannot establish the value of jewelry and the trial court can only take judicial notice of the value of
goods which is a matter of public knowledge or is capable of unquestionable demonstration.

Facts:
1. Spouses Gregorio Tactacan (GREGORIO) and Lilia Tactacan were robbed while on board their passenger-type jeepney. Lilia
was killed. Among the items taken was Gregorio’s Seiko wristwatch.
2. Accused Armando Reanzares (REANZARES) was charged with and found guilty of the crime of Highway Robbery with
Homicide.
3. For the Seiko wristwatch, the TC ordered Reanzares to pay P2,500 which is the value of the same according to the prosecution.
No receipts or any other competent evidence were presented to prove its value.

Issue: W/N the TC may take judicial notice of the value of Gregorio’s wristwatch.

Ruling: NO.
1. The amount of P2,500.00 as reimbursement for the Seiko wristwatch taken from Gregorio must be deleted in the absence of
receipts or any other competent evidence aside from the self-serving valuation made by the prosecution.

An ordinary witness cannot establish the value of jewelry and the trial court can only take judicial notice of the value of goods
which is a matter of public knowledge or is capable of unquestionable demonstration. The value of jewelry therefore does not
fall under either category of which the court can take judicial notice.

WHEREFORE, the TC decision is MODIFIED deleting the amount of P2,500 as reimbursement for the wristwatch.