Relevancy of Facts & Res Gestae
1. Foundations of Relevancy (Articles 2 & 18)
- Definition of Relevancy (Art. 2): One fact is relevant to another when it is connected in any of the ways referred to in the provisions of the QSO.
- Fact in Issue: A core fact that is asserted by one party and denied by the other in a case.
- Scope of Evidence (Art. 18): Evidence can only be given regarding the existence or non-existence of a fact in issue and relevant facts, and of no others.
2. Res Gestae (Article 19)
- Meaning: Literally translates to "things done." It means facts that are closely connected to a fact in issue.
- Rule: Facts which form part of the same transaction are relevant, whether they happened at the same time/place or different times/places.
- Key Illustration: If A is accused of murdering B by beating him, whatever was said or done by A, B, or the bystanders at the beating (or shortly before/after) is a relevant fact.
3. Occasion, Cause, and Conduct (Articles 20, 21, & 22)
- Art. 20 (Causation/Opportunity): Facts constituting the occasion, cause, effect, or opportunity of a fact in issue are relevant.
- Art. 21 (Motive, Preparation, Conduct):
- Art. 22 (Introductory/Explanatory Facts & Identification):
4. Special Scenarios (Articles 27, 28, 46, & 59)
- Art. 27 (State of Mind/Body): If A is caught with a stolen item, the fact that he was in possession of many other stolen articles at the same time is relevant to prove guilty knowledge.
- Art. 28 (Accidental vs. Intentional): When determining whether an act was accidental or intentional, the fact that such an act formed part of a series of similar occurrences is relevant.
- Art. 46 (Account Books): Regular business account entries are relevant but are not sufficient on their own to prove a debt without other evidence.
- Art. 59 (Expert Opinion): When determining if a person was poisoned, the opinion of a medical officer (expert) is relevant.