Title
People vs. Palalon
Case
G.R. No. 25302
Decision Date
Jul 31, 1926
A plantation foreman is convicted of homicide for fatally striking a 10-year-old boy, overriding defense claims of additional contributing factors to the child's death.
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Case Digest (G.R. No. 25302)

Facts:

  • Graciano Palalon was the defendant-appellant; the People of the Philippine Islands were the plaintiff-appellee.
  • The incident occurred on July 20, 1925, in Basac, Bais, Oriental Negros.
  • Palalon was a foreman supervising children, including 10-year-old Roman Megio, who was gathering sugar cane.
  • Roman was resting instead of working, prompting Palalon to reprimand him.
  • Roman responded insolently, questioning Palalon's authority and making derogatory remarks.
  • In anger, Palalon struck Roman on the mouth with the back of his hand.
  • Witnesses for the prosecution claimed Roman fell backward onto a tramway rail, sustaining injuries and bleeding.
  • Defense witnesses contended that Roman did not fall or bleed and that the incident occurred away from the tramway.
  • Roman continued to work until the next afternoon but later fell ill with a fever and died two and a half days after the incident.
  • The prosecution argued that Roman's death resulted from internal injuries caused by the blow, supported by Dr. Jose V. Valero's testimony.
  • The defense argued that Roman's ability to work after the incident raised doubts about the prosecution's claims.
  • The trial court convicted Palalon of homicide, sentencing him to twelve years of reclusion temporal and ordering indemnification for the heirs.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed the lower court's judgment, acquitting Graciano Palalon of homicide.
  • The Court found reasonable doubt regarding the cause of Roman Megio's death.
  • Although Palalon could be convicted of lesiones, he had already s...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the principle of reasonable doubt concerning the causation of Roman Megio's death.
  • While it was acknowledged that Palalon struck Roman, the evidence did not convincingly link this act to the boy's death.
  • The prosecution...continue reading

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