Title
Krohn vs. Court of Appeals
Case
G.R. No. 108854
Decision Date
Jun 14, 1994
A marriage annulment case hinges on the admissibility of a psychiatric report as evidence of psychological incapacity, contested under physician-patient privilege. The Supreme Court ruled the report admissible, affirming the husband's right to testify and dismissing procedural objections.

Case Summary (G.R. No. 108854)

Facts

Edgar Krohn, Jr. and Ma. Paz Fernandez were married on 14 June 1964 and had three children. Marital relations deteriorated; Ma. Paz underwent psychological testing in 1971. The couple separated in fact in 1973. Edgar obtained a copy of the psychiatric report in 1975. The Tribunal Metropolitanum Matrimoniale relied on the report among other matters to render a decree nullifying the church marriage in 1978, confirmed in 1979. A conjugal partnership dissolution was granted in 1982. Edgar filed a civil annulment petition in the Regional Trial Court on 23 October 1990, alleging psychological incapacity and attaching the confidential psychiatric evaluation report. At a 1991 hearing Edgar attempted to testify to the report’s contents; Ma. Paz objected on physician-patient privilege grounds and filed a Manifestation and a Statement for the Record reiterating her denial of the grounds.

Procedural history

The trial court admitted the psychiatric report into evidence by order dated 4 June 1991, overruling the privilege objection and allowing Edgar to testify to the report’s contents. Motions for reconsideration were denied. The Court of Appeals dismissed Ma. Paz’s petition for certiorari on 30 October 1992 and denied reconsideration on 5 February 1993. The petition to the Supreme Court followed.

Issues presented

  1. Whether the physician-patient privilege under Section 24(c), Rule 130, bars a non-physician (the patient’s husband) from testifying to or introducing the contents of a confidential psychiatric report prepared by physicians.
  2. Whether the petitioner waived the privilege by prior conduct or by failing to timely object on other evidentiary grounds (e.g., hearsay).
  3. Whether the Statement for the Record filed by petitioner should be admitted or struck from the record.

Petitioner’s contentions

Petitioner argued that the physician-patient privilege should bar not only physicians from testifying but also third persons (here, the husband) from disclosing privileged communications or submitting confidential medical reports. She emphasized the policy reasons behind the privilege — to ensure full and confidential disclosure to physicians and to protect the patient from humiliation and breach of privacy — and asserted that indirect disclosure by a third party would subvert the rule’s purpose. She also maintained that her Statement for the Record merely reiterated her Answer and should not have been stricken.

Respondent’s contentions

Edgar argued the statutory privilege applies only to physicians and does not prohibit third persons from testifying about medical reports they possess. He further asserted that a husband may testify against his wife in a civil case between them, and that privileged communication may be waived. Edgar claimed petitioner had waived any privilege by consenting to use of the report before the Tribunal Metropolitanum Matrimoniale and by failing to specifically object in her Answer (where she described the report as “either unfounded or irrelevant”). He also contended that the Statement for the Record effectively amounted to an amendment requiring compliance with rules on pleadings.

Legal standard on physician-patient privilege (Lim)

The Court relied on Lim v. Court of Appeals to set requisites for invoking physician-patient privilege: (a) the privilege is claimed in a civil case; (b) the person against whom the privilege is claimed is a practitioner duly authorized to practice medicine, surgery, or obstetrics; (c) the information was acquired while attending to the patient in a professional capacity; (d) the information was necessary for the practitioner’s professional action; and (e) the information was confidential and, if disclosed, would blacken the patient’s reputation. These elements frame whether Section 24(c) operates to bar testimony.

Court’s analysis on applicability of the privilege to the husband’s testimony

Applying the Lim requisites, the Court found the privilege did not bar the husband’s testimony because the person against whom the privilege was claimed was not a physician but the patient’s husband. Section 24(c) disqualifies “a surgeon authorized to practice medicine, surgery or obstetrics” from testifying on matters learned in confidence; it does not by its terms disqualify third persons who acquired a report from testifying. Consequently, petitioner’s insistence that third-party testimony should be prohibited as an indirect circumvention of the privilege was rejected: the statutory prohibition does not extend to non-physicians, and testimony by a third party does not substitute for or have the same force as testimony by the physician who prepared the report.

Court’s ruling on waiver and evidentiary objections (hearsay)

The Court further held that petitioner’s counsel failed to timely raise a hearsay objection at trial. Counsel objected on the ground of privileged communication but did not object that Edgar’s testimony constituted hearsay. By failing to raise hearsay timely, counsel waived that objection and allowed admission of the evidence. The Court emphasized that counsel’s omission was fatal to that line of objection. The Court also noted petitioner’s prior c

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