GR 1785; (July, 1905) (Digest)
G.R. No. 1785 : July 17, 1905
PARTIES:
Plaintiff-Appellee: Shannon Richmond (a doctor)
Defendant-Appellant: Francisco Anchuelo (a blind patient)
FACTS:
The defendant, Francisco Anchuelo, who was blind, engaged the services of the plaintiff, Dr. Shannon Richmond, to treat his eyes. The treatment was unsuccessful. Dr. Richmond filed an action to recover payment for his professional services. A dispute arose regarding the exact terms of their contract. The plaintiff claimed the agreement was that he would receive 200 pesos regardless of the outcome, with an additional 500 pesos if he successfully cured the defendant’s blindness. Conversely, the defendant contended that the contract stipulated payment of 200 pesos only if a cure was effected, and nothing if the treatment failed. The trial court found the evidence in favor of the plaintiff’s version. During the trial, the defendant attempted to present a witness, Jose Pastor, to testify that the defendant had told him (Pastor) about the alleged terms (cure for 200 pesos, nothing if no cure). The trial judge excluded this testimony.
ISSUE:
Was the trial court correct in excluding the testimony of Jose Pastor regarding the defendant’s out-of-court statements about the terms of the contract?
RULING:
Yes, the trial court correctly excluded the testimony. The Supreme Court affirmed the judgment of the lower court.
The proffered testimony was inadmissible under Section 276 of the Code of Civil Procedure (the precursor to the rules on hearsay evidence). The witness, Jose Pastor, had no personal knowledge of the conversation between the plaintiff and the defendant. He could only testify about what the defendant told him the plaintiff had said. This constitutes hearsay, as it is an out-of-court statement offered to prove the truth of its contents (the terms of the contract). Since the witness had no direct knowledge of the contract’s formation and was merely relaying the defendant’s self-serving narration, his testimony was properly excluded.
The Supreme Court also found that the trial court’s factual finding on the contract termssupporting the plaintiff’s claimwas substantiated by the evidence. Therefore, the judgment in favor of the plaintiff was affirmed.