statements to police officers and her daughter about an assault
committed on her by her boyfriend. The trial judge indicated,
at para. 127, that he had looked for, and found, “corroboration”
of the complainant’s allegations in her statements to her daughter and the officers. He also concluded, at para. 116, that
the complainant was consistent in describing what happened
because “. . . she told essentially the same things to Sergeant
Pulfer, Constable Deschamps and again in the police audio-video
 In concluding that the trial judge erred in his use of the
prior consistent statements, this court made the following com-
ments, at paras. 10-12:
. . . the trial judge relied upon certain statements admitted, in some cases
at least, as part of the res gestae, as confirmation of the complainant’s
The relevant evidence was provided by the complainant’s daughter and
several police witnesses who, as I have said, responded to the 911 call. The
daughter’s evidence was proffered by the Crown under the common law res
gestae exception and admitted on that basis. To the extent that the statements coincided with the complainant’s trial evidence, they were prior consistent statements not admissible for their truth, and thus not capable of
providing substantive support for the complainant’s testimony. Their use
however, was not so limited.
. . . . .
. . . The evidence upon which (the trial judge) relied as confirmation consisted of an amalgam of inadmissible opinion and of evidence of the complainant’s statements that was properly admissible for one purpose, but not
for that purpose used by the trial judge.
 The Crown argues that the court’s comments in
Mackenzie could be interpreted as meaning that statements admitted
under the res gestae exception to the hearsay rule are not capable of providing substantive support for consistent testimony.
 Given that in this case the res gestae exception to the
hearsay rule is not operative, the issue of the suggested interpretation of Mackenzie raised by the Crown is not relevant to the
 I will state that I do not interpret the comments in
Mackenzie in the same manner as the Crown. In my view, the cited
passage stands for the correct principle that a prior consistent
statement that is admitted under the res gestae hearsay exception will have limited permissible uses. For example, there is no
added value in the fact that the same statement was repeated;
the value, if any, comes from the context and circumstances in
which the admissible hearsay statement was made: Paciocco,