Prior consistent statement admissible?

R. v. Edgar, 2010 ONCA 529 deals with when a prior consistent statement can be adduced in the criminal context:

[24]          For the following reasons, I conclude that the spontaneous exculpatory statements made by an accused person upon or shortly after arrest may be admitted as an exception to the general rule excluding prior consistent statements for the purpose of showing the reaction of the accused when first confronted with the accusation, provided the accused testifies and thereby exposes himself or herself to cross-examination.

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[35]          It is well recognized, however, that the prior consistent statements of an accused are not always excluded.  Two established exceptions have already been mentioned.  First, where an accused's prior consistent statement is relevant to his or her state of mind at the time the offence was committed, it may be admitted.  Second, where the Crown alleges recent fabrication, the accused may adduce evidence of a prior consistent statement to rebut the allegation.  A third exception is made for "mixed" statements that are partly inculpatory and partly exculpatory.  Where the Crown seeks to adduce evidence of such a statement, the inculpatory portion is admissible as an admission against interest and, as a matter of fairness to the accused, the Crown is required to tender the entire statement, with the exculpatory portion being substantively admissible in favour of the accused: Rojas, at para. 37.  A fourth exception is that the prior statement will be admitted where it forms part of the res gestae, in other words, where the statement itself forms part of the incident that gives rise to the charge: see Graham; R. v. Risby, [1978] 2 S.C.R. 139.