Comparative study reveals divergent evidence systems in China and the Philippines, suggesting reforms for legal cooperation.
Against the backdrop of economic globalization and deepening regional cooperation, legal exchanges and judicial cooperation between China and the Philippines are becoming increasingly frequent. Especially in the field of criminal justice, understanding the differences in evidence systems has become the key to transnational law enforcement cooperation and legal aid. This paper compares the evidence systems in criminal justice in China and the Philippines, combs through the historical origins and legal basis of each system, systematically compares the core contents such as types of evidence, exclusionary rules for illegal evidence, witness system, protection of defendant's rights and adoption of electronic evidence, and combines typical case analysis to reveal the fundamental differences between the two systems in terms of value orientation and institutional operation. The study found that the Philippine system focuses more on procedural justice and constitutional protection, while the Chinese system focuses on substantive truth and case handling efficiency. On this basis, this paper puts forward several targeted reform suggestions, such as improving the procedure for excluding illegal evidence, strengthening the mechanism for witnesses to appear in court, promoting the implementation of the cross-examination system, improving the standardization of electronic evidence acceptance, and strengthening the protection of procedural rights such as the right to remain silent, in order to provide international experience and path inspiration for the reform of China's criminal evidence system.
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Yun Pei (2025) studied this question.
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