Before
a tape recording is admissible in evidence and given probative value, the
following requisites must first be established, to wit: (1) a
showing that the recording device was capable of taking testimony; (2) a
showing that the operator of the device was competent; (3) establishment
of the authenticity and correctness of the recording; (4) a
showing that changes, additions, or deletions have not been made; (5) a
showing of the manner of the preservation of the recording; (6) identification
of the speakers; an (7) a showing that the testimony elicited was
voluntarily made without any kind of inducement. In one case, it was held that the testimony
of the operator of the recording device as regards its operation, his
method of operating it, the accuracy of the recordings, and the identities of
the persons speaking laid a sufficient foundation for the admission of the
recordings. Likewise, a witness' declaration that the sound
recording represents a true portrayal of the voices contained therein satisfies
the requirement of authentication. The party seeking the introduction in
evidence of a tape recording bears the burden of going forth with sufficient
evidence to show that the recording is an accurate reproduction of the
conversation recorded. These requisites were laid down precisely to address the
criticism of susceptibility to tampering of tape recordings. Thus, it was held
that the establishment of a proper foundation for the admission of a recording
provided adequate assurance that proper safeguards were observed for the
preservation of the recording and for its protection against tampering. (Torralba vs. People [2005]).
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