Evidence Digest: PEOPLE OF THE PHILIPPINES vs. JOSEPH LEONES (1982)

Topic: Official Records (Rule 130, Section 44)

PEOPLE OF THE PHILIPPINES vs. JOSEPH LEONES
[117 SCRA 382 / G.R. No. L-48727 September 30, 1982] 

Facts:
This is an appeal filed by the accused, who was found guilty of rape. He was the son of the store owner and the victim was a salesgirl employed therein.

On review, the Supreme Court had considered pieces of recorded evidence such as the written entries in the clinical case record prepared and signed by the admitting physician of the hospital. It shows the date of the victim's admission in the hospital, her complaint of vaginal bleeding and the diagnosis of "Healing lacerated wide at 2 o'clock and 10 o'clock hymen".

Issue:
If the entries in the medical record made by the physician in a government hospital  is admissible as the exception to the hearsay rule?

Held:
YES. The said entries having been made in official records by a public officer of the Philippines in the performance of his duty especially enjoined by law, which is that of a physician in a government hospital is prima facie evidence of the facts therein stated.