It is within the sound discretion of the trial judge to determine whether a witness will be permitted to testify in a narrative form.
Facts: Appellant Calixtro was convicted of the crime of rape. On appeal, he contends that the trial court erred in allowing the complainant-witness to testify in narrative form.
Held: Usually in criminal cases, the material facts within the knowledge of a witness are elicited by questions put to him by the counsel calling him. By this means, the evidence is readily limited and confined within the issue for the reason that the relevancy of the answer can in most cases be ascertained from the character of the question (Underhill's Criminal Evidence, Sec. 387, p. 742). While this is the general rule, it still rests within the sound discretion of the trial judge to determine whether a witness will be required to testify by question and answer, or will be permitted to testify in a narrative form (98 C.J.S., Sec. 325, p. 26). There is no legal principle which prevents a witness from giving his testimony in a narrative form if he is requested to do so by counsel. A witness may be allowed to testify by narration if it would be the best way of getting at what he knew or could state concerning the matter at issue. It would expedite the trial and would perhaps furnish the court a clearer understanding of the matters related as they occurred. Moreover, narrative testimony may be allowed if material parts of his evidence cannot be easily obtained through piecemeal testimonies. But if, in giving such testimony, the witness states matters irrelevant or immaterial or incompetent, it is the right and duty of counsel objecting to such testimony to interpose and arrest the narration by calling the attention of the court particularly to the objectionable matter and, by a motion to strike it out, obtain a ruling of the court excluding such testimony from the case (98 C.J.S., Ibid.). While a witness may be permitted in the discretion of the court to narrate his knowledge of material facts bearing upon the case without specifically being interrogated in detail, it is also within the discretion of the court to prohibit a witness from volunteering unsought information in connection with the case (5 Jones on Evidence, Sec. 2312). [People of the Philippines vs Pedring Calixtro, G.R. No. 92355, January 24, 1991]
