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Espineli Vs People

1) NBI Agent Segunial testified that he took a sworn statement from Reyes where Reyes stated that he overheard the accused tell Sotero "Ayaw ko nang abutin pa ng bukas yang si Berbon" and saw them armed before boarding a red car. 2) The accused argued this sworn statement was inadmissible hearsay evidence. 3) The Court held the testimony was not hearsay because it was presented not for the truth of the statement, but only to establish that Reyes made the statement. As such, it falls under the doctrine of independently relevant statements where the making of the statement itself is relevant, regardless of its truth.

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Lourdes Lescano
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772 views2 pages

Espineli Vs People

1) NBI Agent Segunial testified that he took a sworn statement from Reyes where Reyes stated that he overheard the accused tell Sotero "Ayaw ko nang abutin pa ng bukas yang si Berbon" and saw them armed before boarding a red car. 2) The accused argued this sworn statement was inadmissible hearsay evidence. 3) The Court held the testimony was not hearsay because it was presented not for the truth of the statement, but only to establish that Reyes made the statement. As such, it falls under the doctrine of independently relevant statements where the making of the statement itself is relevant, regardless of its truth.

Uploaded by

Lourdes Lescano
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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281

ESPINELI vs PEOPLE
G.R. No. 179535
June 9, 2014
DEL CASTILLO, J.:

DOCTRINE: . Regardless of the truth or falsity of a statement, when what is relevant is the fact
that such statement has been made, the hearsay rule does not apply and the statement may be
shown. As a matter of fact, evidence as to the making of the statement is not secondary but
primary, for the statement itself may constitute a fact in issue or is circumstantially relevant as to
the existence of such a fact. This is known as the DOCTRINE OF INDEPENDENTLY
RELEVANT STATEMENTS.

FACTS: Accused together with Sotero and three others shot Alberto Berbon with the use of
firearms, causing his instantaneous death, and thereafter immediately fled the crime scene on
board a waiting car. An Information for Murder was filed before RTC.  Meanwhile, the NBI
arrested Reyes for another crime. He confided to the NBI that he was willing to give vital
information regarding the Berbon case. Reyes claimed that he saw accused and Sotero board a
red car while armed with a .45 caliber firearm and armalite, and that accused told Sotero that
“ayaw ko nang abutin pa ng bukas yang si Berbon.” Subsequently, Reyes jumped bail and was
never again heard of. NBI Agent Segunial reduced his statement into writing and testified on
these facts during the trial. Prosecution also presented a witness who testified that he sold his
red Ford Escort car to three persons and identified the said car from the photographs. Accused
filed a Demurrer to Evidence without leave of court. 

RTC convicted the accused for Murder. On appeal, CA convicted the accused for Homicide.
 
Accused filed a Petition for Review on Certiorari. Petitioner anchors his quest for the reversal of
his conviction on the alleged erroneous admission in evidence of the Sinumpaang Salaysay of
Reyes for being hearsay and inadmissible. He avers that the said sworn statement should not
have been given probative value because its contents were neither confirmed nor authenticated
by the affiant. He emphasizes that there was no direct evidence linking him to the crime.

ISSUE: Whether the testimony of NBI Agent Segunial can be regarded as hearsay evidence

HELD:

No. NBI Agent Segunial testified that he had investigated Reyes and reduced the latter’s
statement into writing declaring, among others, that Reyes overheard petitioner telling Sotero
“Ayaw ko nang abutin pa ng bukas yang si Berbon” and saw them armed with .45 caliber pistol
and an armalite, respectively, before boarding a red car. Petitioner insists that the said sworn
statement belongs to the category of hearsay evidence and therefore inadmissible. He asserts
that its contents were never confirmed or authenticated by Reyes, thus, it lacks probative value.

The hearsay evidence rule as provided under Section 36, Rule 130 of the Rules of Court states:
Sec. 36. Testimony generally confined to personal knowledge; hearsay excluded. – A witness
can testify only to those facts which he knows of his personal knowledge; that is, which are
derived from his own perception, except as otherwise provided in these rules.
Evidence is hearsay when its probative force depends in whole or in part on the competency
and credibility of some persons other than the witness by whom it is sought to produce.
However, while the testimony of a witness regarding a statement made by another person given
for the purpose of establishing the truth of the fact asserted in the statement is clearly hearsay
evidence, it is otherwise if the purpose of placing the statement on the record is merely to
establish the fact that the statement, or the tenor of such statement, was made. Regardless of
the truth or falsity of a statement, when what is relevant is the fact that such statement has been
made, the hearsay rule does not apply and the statement may be shown. As a matter of fact,
evidence as to the making of the statement is not secondary but primary, for the statement itself
may constitute a fact in issue or is circumstantially relevant as to the existence of such a fact.
This is known as the DOCTRINE OF INDEPENDENTLY RELEVANT STATEMENTS.

In the present case, the testimony of NBI Agent Segunial cannot be regarded as hearsay
evidence. This is considering that it was not presented to prove the truth of such statement but
only for the purpose of establishing that Reyes executed a sworn statement containing such
narration of facts. This is clear from the offer of the witness’ oral testimony. What the
prosecution sought to be admitted was the fact that Reyes made such narration of facts in his
sworn statement and not necessarily to prove the truth thereof. Thus, the testimony of NBI
Agent Segunial is in the nature of an independently relevant statement where what is relevant is
the fact that Reyes made such statement and the truth and falsity thereof is immaterial. In such
a case, the statement of the witness is admissible as evidence and the hearsay rule does not
apply.

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