Independently relevant statements are not barred by the hearsay rule.

See -  https://lawphil.net/judjuris/juri2007/feb2007/gr_174056_2007.html


THE PEOPLE OF THE PHILIPPINES, Appellee, vs. ROGELIO GUMIMBA y MORADANTE alias ROWING and RONTE ABABO (acquitted), Appellants. G.R. No. 174056, [Formerly G.R. No. 138257, February 27, 2007.


“x x x.

Appellant challenges the testimonies of the witnesses Magallano and Arañas on what appellant had confessed to or told them for being hearsay. The challenge fails. The testimonies, it should be conceded, cannot serve as a proof of extrajudicial confession for an extrajudicial confession has to be in writing, among others, to be admissible in evidence.42 That is why the testimonies are of use in the case as corroborative evidence only. Such utility, however, cannot be defeated by the hearsay rule. The testimonies covered are independently relevant statements which are not barred by the hearsay rule.

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. 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.43

Moreover, where, as in the case at bar, there is no evidence to show any dubious reason or improper motive for a prosecution witness to bear false testimony against the accused or falsely implicate him in a crime, his or her testimony should be given full faith and credit.44

X x x.”