see - sc.judiciary.gov.ph/jurisprudence/2013/july2013/179786.pdf
"x x x.
1. The case presents a procedural issue, given that the time to object to the admission of evidence, such as the hospital records, would be at the time they are offered. The offer could be made part of the physician’s testimony or as independent evidence that he had made entries in those records that concern the patient’s health problems.
Section 36, Rule 132, states that objections to evidence must be made after the offer of such evidence for admission in court. Thus:
SEC. 36. Objection.— Objection to evidence offered orally must be made immediately after the offer is made.
Objection to a question propounded in the course of the oral examination of a witness shall be made as soon as the grounds therefor shall become reasonably apparent.
An offer of evidence in writing shall be objected to within three (3) days after notice of the offer unless a different period is allowed by the court.
In any case, the grounds for the objections must be specified.
Since the offer of evidence is made at the trial, Josielene’s request for
subpoena duces tecum is premature. She will have to wait for trial to begin
before making a request for the issuance of a subpoena duces tecum
covering Johnny’s hospital records. It is when those records are produced
for examination at the trial, that Johnny may opt to object, not just to their admission in evidence, but more so to their disclosure. Section 24(c), Rule
130 of the Rules of Evidence quoted above is about non-disclosure of
privileged matters.
x x x."
