SC Dismisses Disbarment Case Against Lawyers, Sets Guidelines on Proving Screenshots as Evidence in Court

SC Dismisses Disbarment Case Against Lawyers, Sets Guidelines on Proving Screenshots as Evidence in Court |

BY ATTY. PHIL JURIS | June 27, 2025

In Serrano v. Cruz-Angeles (A.C. No. 10985, July 29, 2024), the Supreme Court dismissed an administrative complaint for disbarment filed against Atty. Rose Beatrix Cruz-Angeles and Atty. George Ahmed Paglinawan after the complainant failed to establish the authenticity and authorship of Facebook posts allegedly made by the respondents. While the complaint was dismissed, the decision is notable for reaffirming and clarifying the rules governing the admissibility of screenshots and digital printouts as evidence in court proceedings.

At the heart of the decision is a critical reminder: screenshots and digital documents are not self-authenticating. Their admissibility hinges on compliance with the Rules on Electronic Evidence (A.M. No. 01-7-01-SC), particularly Rule 5 on authentication.

Authentication Requirements Under the Rules on Electronic Evidence

Pursuant to Rule 5, Section 1, the burden of proving the authenticity of an electronic document rests on the party offering it in evidence. This requirement applies whether the document is presented in its digital form or as a printed copy.

Under Section 2 of the same rule, a private electronic document may be authenticated in any of the following ways:

1. By Digital Signature
   Authentication may be established through evidence that the document was digitally signed using a secure key pair. A digital signature serves as proof of authorship and document integrity.

2. By Recognized Security Procedures or Devices
   The proponent may present evidence that the document was subjected to authentication protocols, such as encryption, secure hash algorithms, or verified audit trails, consistent with those authorized by law or the Supreme Court.

3. By Other Evidence of Integrity and Reliability
   In the absence of digital signatures or technological safeguards, other forms of evidence may be admitted to satisfy the court that the document is genuine. These include:

   • Testimony from a person who captured or witnessed the creation of the content;

   • Forensic examination or expert certification as to the document’s source and unaltered condition;

   • Metadata or log data reflecting the time, date, and origin of the content;

   • Circumstantial evidence linking the document or account to the person alleged to have authored it.

Notably, the Court emphasized that mere attachment of a screenshot to a pleading is insufficient, particularly when authorship is contested. In Serrano, the complainant failed to submit any corroborating evidence—technical or testimonial—linking the Facebook posts to the respondents. As a result, the posts were deemed unauthenticated and without evidentiary value.

Admissibility of Printouts Under the Best Evidence Rule

The decision also underscores the application of Rule 4 of the REE. An electronic document—whether viewed digitally or as a printout—may be regarded as the functional equivalent of an original, provided it is shown to accurately reflect the data contained in the original electronic file.

However, Section 2 of Rule 4 imposes limitations. A printout may not be treated as an original if there is a genuine issue as to the authenticity of the source, or if its admission would be unjust or inequitable under the circumstances. This reinforces the need to establish both the factual accuracy of the document and the legitimacy of its source.

Ownership, Authorship, and Chain of Custody

One of the key principles reiterated by the Court is that the proponent of a screenshot must not only prove its content but also its source. The identity of the account holder, the origin of the post, and the unbroken chain of custody from the time it was captured to the time it is presented in court must be clearly demonstrated.

Failure to establish these elements, particularly when the alleged author denies authorship, renders the document inadmissible and devoid of probative weight.

Serrano v. Cruz-Angeles (A.C. No. 10985, July 29, 2024), per LAZARO-JAVIER, J.