Section 4. Relevancy; collateral matters

Evidence must have such a relation to the fact in issue as to induce belief in its existence or non-existence. Evidence on collateral matters shall not be allowed, except when it tends in any reasonable degree to establish the probability or improbability of the fact in issue.

To illustrate the above section: 

1. Case of annulment filed by wife. At every hearing of the case the husband is always accompanied by his mother. In this scenario, the lawyer must manifest and put on the record that the mother is always present. At first instance, the manifestation is irrelevant or collateral matter. However, it may prove the immaturity, childishness, or mama’s boy of the son, the husband. Hence, it tends in some reasonable degree to establish the psychological incapacity of the husband.

2. Case of slight physical injury. Accused has the habit of always bringing an umbrella. In this scenario, the prosecutor must manifest and put on the record that accused is always bringing an umbrella. At the outset, the manifestation is irrelevant or collateral matter. But it may prove that the injury sustained by the private complainant is due to a blatant instrument like an umbrella.

There are cases however that evidence need be presented. These are provided in Rule 129 of the Rules on Evidence, to quote:

“Section 1. Judicial notice, when mandatory. – A court shall take judicial notice, without the introduction of evidence, of the existence and territorial extent of states, their political history, forms of government and symbols of nationality, the law of nations, the admiralty and maritime courts of the world and their seals, the political constitution and history of the Philippines, official acts of the legislative, executive and judicial departments of the National Government of the Philippines, the laws of nature, the measure of time, and the geographical divisions”.

There are other matters or issues things that need not be proved although not listed in the judicial notice and these are the following:

1. An accused enjoys the presumption of innocence — he need not prove what is legally presumed. (Madrid v. Court of Appeals, 332 SCRA 570).

2. It is a settled rule in our jurisdiction that the duly accomplished form of the Civil Service is an official document of the Commission, which, by its very nature, is considered in the same category as that of a public document, admissible in evidence without need of further proof – as an official document, the entries thereof made in the course of official duty are prima facie evidence of the facts stated therein. (Office of the Court Administrator v. Bermejo, 548 SCRA 219).
3. Judicial admission. — An admission, verbal or written, made by the party in the course of the proceedings in the same case, does not require proof. The admission may be contradicted only by showing that it was made through palpable mistake or that no such admission was made. (Sec. 4, Rule 129).

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