A complaint consisting only of a nod in response to a mother's question 'Did he touch you on the wee?' is admissible as recent complaint evidence where the complaint was proximate to the event, made at the first opportunity, and the question merely dissolved the barrier preventing the complainant from telling her story rather than implanting a suggestion. The four-factor test from Freeman (proximity, no statements put in mouth, no suggestive question to suggestible mind, no inducement from relationship) was applied and satisfied.
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