Upchurch v. Commonwealth
In Upchurch v. Commonwealth, 220 Va. 408, 258 S.E.2d 506 (1979), the Virginia Supreme Court held that a detective's testimony that he responded to a radio report of a "burglary in progress" was not hearsay because the "hearsay rule does not operate to exclude evidence of a statement . . . offered for the mere purpose of explaining or throwing light on the conduct of the person to whom it was made." Id. at 410, 258 S.E.2d at 508.