ESTRADA v.

DESIERTO367 SCRA 108 (2001) Doctrine: The ban on hearsay does not cover independently relevant
statements, which consist of statements that are independently relevant of the truth asserted therein. They belong to
two classes: 1. Those statements which are the very facts in issue, 2. Those statements which are circumstantial
evidence of the facts in issue. The second class includes the following: Statement of a person showing his state of
mind; Statement of a person showing his physical condtion; Statement of a person to infer a state of mind of another
person; Statements which may identify the date, place and person in question ;Statements to show a lack of

credibility of a witness.

FACTS: The case at bar stemmed from the events that transpired during EDSA II. President Joseph Estrada
pursuant to the calls for resignation, left Malacanang, and pursuant to this, Gloria Macapagal-Arroyo, then the Vice
President under Estrada’s reign took his place. Estrada now goesto the court to contest the legitimacy of Macapagal-
Arroyo’s presidency, arguing that he never resigned as President, and hence, claims to still be the lawful President of the
Philippines. Among the pieces of evidence offered to prove that Estrada had indeed resigned from the presidency is
the Angara Diary, chronicling the last moments of Estrada in Malacanang.

ISSUE: 1. Whether the Angara Diary is inadmissible as hearsay evidence? - NO.

RATIO: The Supreme Court held that the Angara diary is not an out0of0court statement but is a part of the
pleadings of the case. Furthermore, the Court noted that the Angara diaries contained direct statements of Estrada
with respect to his proposal for the holding of a snap election, his intent to leave his post by Monday and his exasperation over
the bureaucracy, controversy and red tape. An ANALYSIS of the same leads to the conclusion that the contents of the
diary may be more accurately classified as admissions of a party. Pursuant to the Rules of Evidence, “the act,
declaration or omission of a party as to a relevant fact may be given in evidence against him. Moreover, the statements
cannot be regarded as hearsay evidence because the same can be properly categorized as independently relevant statements.
Independently relevant statements are those which are “independent” from the truth of the statements. Independently
relevant statements may be classified into statements which consist of the very facts in issue and those which are
circumstantial evidence of the facts in issue, such as the statements of a person showing his state of mind or
statements of a person from which an inference may be made as to the state of mind of another. Pursuant to this, it
may well be said that the entries in the Angara diary may be regarded as containing statements regarding the state of
mind of Estrada, hence constituting circumstantial evidence of his intent to resign.