As an
exception to the rule against hearsay evidence, a dying declaration or ante
mortem statement is evidence of the highest order and is entitled to
utmost credence since no person aware of his impending death would make a
careless and false accusation.
In order for a dying declaration to be held admissible, four requisites must concur: first, the declaration must concern
the cause and surrounding circumstances of the declarant's death; second, at the time the declaration
was made, the declarant must be under the consciousness of an impending death;
third, the declarant is competent
as a witness; and fourth, the
declaration must be offered in a criminal case for homicide, murder, or
parricide, in which the declarant is the victim.
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