Doctrine of independently relevant statements

See -  https://www.lawphil.net/judjuris/juri2018/jul2018/ac_8962_2018.html


JILDO A. GUBATON, Complainant, vs. ATTY. AUGUSTUS SERAFIN D.AMADOR, Respondent. A.C. No. 8962, JULY 9, 2018.


“x x x.

Finally, it should be clarified that while the information supplied by complainant and Bernadette's house helper and Bernadette's clinic secretary about the alleged illicit affair constitute hearsay, the same should not be completely disregarded. 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 doctrine on independently relevant statements holds that conversations communicated to a witness by a third person may be admitted as proof that, regardless of their truth or falsity, they were actually made. Evidence as to the making of such statements is not secondary but primary, for in itself it (a) constitutes a fact in issue or (b) is circumstantially relevant to the existence of such fact. Accordingly, the hearsay rule does not apply, and hence, the statements are admissible as evidence. 25 Verily, complainant personally attests that the information about the illicit affair between respondent and his wife have been relayed to him by complainant's house helper and Bernadette's clinic secretary. Clearly, the making of such statements is circumstantially relevant to this case and therefore, may be considered in evidence against respondent. X x x.

X x x.”