Validity Period of a Medico-Legal Certificate for Slight Physical Injuries in the Philippines
Key take-away: Philippine law does not fix an “expiration date” for a medico-legal certificate. Its probative value lasts for as long as the document can be authenticated and the findings remain relevant, but timeliness—obtaining, filing and presenting it quickly—can decide whether a criminal case for slight physical injuries survives or prescribes.
1. What is a medico-legal certificate?
A medico-legal certificate (MLC) is the written, signed and usually sworn report of a physician who examines a person allegedly injured by violence or accident. It is documentary evidence under Rule 132 of the Rules of Court, either:
- a public document (if issued by a government doctor or by the PNP Forensic Group) or
- a private document (if issued by a private physician, which then needs authentication in court).
2. “Slight Physical Injuries” under the Revised Penal Code
| Provision | Healing / incapacity period | Penalty | Time bar (“prescriptive period”) for filing the case |
|---|---|---|---|
| Art. 266, RPC | 1 – 9 days medical attendance or incapacity for work of the same duration; or injuries that do not incapacitate and are not covered by Arts. 262–265 | Arresto menor (1 day – 30 days) | 2 months (Art. 90, RPC) |
If the injury incapacitates the victim for 10 – 30 days, the offense elevates to less serious physical injuries (Art. 265).
3. Who may issue the certificate & what must it contain?
| Issuer | Common practice | Essential contents |
|---|---|---|
| Government doctor (public hospital, municipal/city health office) or PNP Forensic Group physician | Usually issued on PNP Crime Laboratory Form “Medicolegal Report”; considered public document | – Identity of examinee – Date, time & place of examination – Detailed description of every injury (size, location, type) – Estimated healing period / days of medical attendance – Estimated days of incapacity for labor (if any) – Examining doctor’s full name, PRC license, PTR no., and signature – Oath/verification administered by a notary or authorized officer |
| Private physician | Written on clinic/hospital letterhead or a standard form | Same substantive items; must be identified and testified to by the doctor if the defense objects |
Good practice: attach photographs, laboratory images, or a separate Supplemental/Final Certificate once the wound has completely healed.
4. The “validity period”: law vs. practical deadlines
| Aspect | What the law says | Practical consequences |
|---|---|---|
| Evidentiary value | No statute invalidates an MLC after a set time. It remains admissible if: 1) original/certified true copy is produced, 2) it is properly identified (or its execution admitted), and 3) the issuing doctor may be cross-examined. | Credibility decreases the longer the delay between injury and examination (see People v. Tuangco, CA-G.R. 77212, 26 June 2003), but courts have still given weight to MLCs issued weeks later when corroborated. |
| Filing the criminal complaint | For slight physical injuries the action prescribes in two (2) months. The prosecutor will normally require an MLC to accompany the complaint-affidavit. | In practice, get examined and secure the certificate within days, and file the complaint well before the 2-month clock runs. |
| Insurance / employment / SSS-EC claims | Each agency has its own rules (most require filing within 30–90 days of the incident). These are policy-based, not statutory. | An “old” certificate may be rejected for benefits processing even if still usable in court. |
| PNP blotter & preliminary investigation | The investigator often asks for a “final” MLC once the healing days have run so the proper article & penalty can be charged. | Delays in submitting this can result in the fiscal downgrading or even dismissal of the case. |
Bottom line: There is no legal expiry date, but treat the certificate as time-sensitive evidence tied to the two-month prescriptive period and to the healing period that defines the offense.
5. Relevant jurisprudence
- People v. Sabijon, G.R. 225055, 13 Feb 2019 – The Court upheld conviction for slight injuries even though the MLC was issued five days after the incident; contemporaneous victim testimony bridged the gap.
- People v. Catubig, G.R. 137842, 23 Aug 2001 – Medical findings in an authenticated MLC are admissible even without the doctor’s testimony when the defense stipulates.
- People v. Manalang, G.R. 119003, 29 Jan 1998 – Where the medical certificate was taken three weeks after the beating and showed only healed scars, the Court gave it little weight but still convicted on eyewitness testimony; illustrates diminishing probative force of delayed exams.
- Soria v. People, G.R. 189071, 3 Apr 2013 – Reiterated that a physician’s sworn MLC is prima facie proof of the facts stated; the burden shifts to the defense to overthrow it.
6. Tips for complainants, lawyers and physicians
- Seek examination within 24 hours whenever possible; earlier exams avoid accusations of fabrication and preserve transient marks (e.g., contusions).
- Request both an Initial and a Final Certificate: the first establishes the existence of the injury; the second confirms the actual healing days.
- Ensure proper oath & notarization so the certificate qualifies as a public document (or becomes easily authenticated as a private one).
- Keep multiple certified copies; courts, prosecutors, and insurance carriers often require originals.
- Have the doctor available to testify; even a flawless certificate may be struck out if the defense insists on cross-examination and the physician is unavailable.
- File the criminal complaint early—do not gamble on the two-month prescription period.
- For insurers/SSS-EC: check the policy circular; many reject certificates issued > 90 days after the incident.
7. Frequently-Asked Questions
| Question | Answer |
|---|---|
| Does my MLC “expire” after six months? | Legally, no. If properly authenticated, the court can rely on it years later. However, agencies processing benefits may impose their own cut-off. |
| I was examined 12 days after the incident; can it still be classified as “slight injuries”? | Possibly not. The doctor must estimate the healing period, not the interval before examination. If healing took only nine days, it is still slight; if more, it becomes less serious injuries. |
| Can a photocopy be used? | Only if the original is unavailable and its loss is explained; the Rules on Secondary Evidence (Rule 130, §5) then apply. |
| What if the doctor already left the country? | Move to admit the MLC as an exception to the hearsay rule under the “public document” or “official record” exceptions, or seek to take the doctor’s deposition de bene esse. |
| Is a barangay health worker’s note enough? | No; only a licensed physician may issue a medico-legal certificate that courts will accept as proof of physical injuries. |
8. Conclusion
While Philippine statutes set no formal shelf-life for a medico-legal certificate, the combination of (a) the two-month criminal prescription for slight physical injuries and (b) the natural fading of evidentiary weight over time makes it essential to secure, submit and, when needed, update the certificate without delay. Courts have consistently treated the document as reliable evidence—provided it is timely, properly executed, and supported (or at least uncontroverted) by medical testimony.
This article is for informational purposes only and does not constitute legal advice. When in doubt, consult a Philippine lawyer or the appropriate prosecuting office.