How the doctrine evolved

While Lacson y Manalo underscored the non-conclusive character of medico-legal reports, the Court in People of the Philippines v. Vasquez (G.R. No. 255496, 31 August 2022, Second Division; Source: Lawphil) refined the analysis by warning against over-reliance on allegations of injury unsupported by medical findings. There, the Court subjected the prosecution’s claims to careful scrutiny and stressed that injury allegations must be coherent with the available medical evidence and the totality of the record.

Doctrinal Evolution: From recognizing medico-legal reports as non-binding (Lacson y Manalo), the doctrine evolved toward heightened judicial scrutiny of injury claims when medical findings are weak, absent, or inconsistent (Vasquez).

Module 1: Injuries, Evidence, and the Human Body

Module 1 Learning Units