The Supreme Court of Pennsylvania has held that when, in a workmen's compensation proceeding, the board is dealing with an unwitnessed occurrence and the party involved has died, statements by the decedent to his doctor to enable the physician to make a proper diagnosis and treatment of decedent's injury and which relate the cause of the injury are admissible as long as there are no circumstances casting suspicion on the genuineness of the utterances.
Cody v. S.K.F. Industries, 447 Pa. 558, 291 A.2d 772 (1972).
Robert A. Berkowitz,
Evidence - Workmen's Compensation - Statement of Cause of an Accident to Physicians Admissible as Proof of Cause of Injury,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol12/iss2/13