See - https://lawphil.net/judjuris/juri2002/dec2002/gr_147649_2002.html
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANK LOBRIGAS, MARLITO LOBRIGAS (At Large) and TEODORICO MANTE (acquitted), accused. FRANK LOBRIGAS, accused-appellant. G.R. No. 147649, December 17, 2002.
“X x x.
Under the doctrine of independently relevant statements, only the fact that such statements were made is relevant, and the truth or falsity thereof is immaterial. The hearsay rule does not apply, hence, the statements are admissible as evidence. Evidence as to the making of such statement is not secondary but primary, for the statement itself may constitute a fact in issue or be circumstantially relevant as to the existence of such a fact.7
X x x.”
