Title
Addenbrook y Barker vs. People
Case
G.R. No. L-22995
Decision Date
Jun 29, 1967
Driver convicted of homicide through reckless imprudence after hitting pedestrian; excessive speed and failure to exercise care upheld despite obstruction claim.

Case Digest (G.R. No. L-22995)

Facts:

William Addenbrook y Barker v. People of the Philippines, G.R. No. L-22995, June 29, 1967, the Supreme Court En Banc, Reyes, J., writing for the Court.

Petitioner William Addenbrook y Barker was driver of a Stanvac service truck involved in a collision on 9 January 1960 at about 3:15 p.m. on Marquez de Comillas. The truck, with petitioner at the wheel and his helper Amando Valeriano aboard, struck pedestrian Wenceslao Risaldo in front of House No. 1010; Risaldo fell, was taken to the Philippine General Hospital, and was dead on arrival. The medico-legal exhibit (Exh. B) showed multiple abrasions, contusions, lacerations and a fractured skull.

The Fiscal filed criminal charges for homicide through reckless imprudence against petitioner. The Court of First Instance of Manila convicted petitioner. On appeal, the Court of Appeals affirmed the conviction, relying on ocular-investigation facts (two sets of bloodstains and that the victim rolled some fifteen paces), the partly obstructed view caused by a parked car in front of House No. 1010, and petitioner’s failure to blow his horn as indicia that the truck was traveling at more than a slow, reasonable speed and that petitioner failed to exercise due care.

Petitioner sought relief in the Supreme Court by a petition for certiorari to review the Court of Appeals decision, assailing the credibility and competency of patrolman Guzman (who performed the ocular inspection) and asserting that the victim sudde...(Pro-only)

Issues:

  • Was the Court of Appeals' finding against petitioner, based on the testimony of patrolman Guzman and other evidence, reviewable by the Supreme Court as a question of law?
  • Does the asserted fact that the pedestrian suddenly darted from behind a parked car excuse petitioner from criminal liability for homicide thr...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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