Payroll Entries Enjoy the Presumption of Regularity but are Overthrown by Doubts on Their Genuineness

Payroll Entries Enjoy the Presumption of Regularity but are Overthrown by Doubts on Their Genuineness

Payroll information enjoys the presumption of regularity as entries made in the course of business. However, this presumption of regularity may be effectively overthrown by evidence to the contrary.

Hence, in the case of Ramiro Lim & Sons Agricultural Co., Inc., vs. Guilaran, et al. (G.R. No. 221967, February 6, 2019), the Supreme Court held that while it is true that entries in the payrolls enjoy the presumption of regularity, it is merely a disputable presumption that may be overthrown by clear and convincing evidence to the contrary.

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Section 43 of Rule 143 of the Rules of Court provides that entries made at, or near the time of transactions to which they refer, by a person deceased, or unable to testify, who was in a position to know the facts therein stated, may be received as prima facie evidence, if such person made the entries in his professional capacity or in the performance of duty and in the ordinary or regular course of business or duty.

However, a presumption is merely an assumption of fact that the law requires to be made based on another fact or group of facts. It is an inference as to the existence of a fact that is not actually known, but arises from its usual connection with another fact, or a conjecture based on past experience as to what the ordinary human affairs take.

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A presumption has the effect of shifting the burden of proof to the party who would be disadvantaged by a finding of the presumed fact. Moreover, prima facie evidence is defined as evidence which, if unexplained or uncontradicted, is sufficient to sustain a judgment in favor of the issue it supports, but which may be contradicted by other evidence.

Thus, prima facie evidence is not conclusive or absolute evidence to the contrary may be presented by the party disputing the assumption of fact made by inference of law and the court may validly consider such.

Where there are inconsistencies in the signatures of employees in the payroll which are questionable to the naked eye that there exists doubt on their genuineness. The employees refute the payrolls submitted as being incomplete, irregular, and forged. They allege that they were never given copies of these payrolls.

The SC held that the allegation that their signatures were forged or signed by unauthorized persons can hardly be overlooked. There were inconsistencies in the signatures and even signatures of unknown or unauthorized persons. The payrolls submitted were self-serving, unreliable, and unsubstantial.

Thus, while the payrolls in question enjoyed the presumption of regularity as entries made in the course of business, this presumption of regularity was effectively overthrown by evidence to the contrary.

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