Title
People vs Barnes
Case
G.R. No. 4774
Decision Date
Nov 18, 1908
A.H. Barnes is acquitted of criminal liability for the death of Pedro Leonardo after unintentionally shooting him while duck hunting, as the court rules that the act was involuntary and free from malice or criminal intent.
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Case Digest (G.R. No. 4774)

Facts:

  • The case The United States vs. A.H. Barnes, G.R. No. 4774, was decided on November 18, 1908.
  • The incident took place during a duck hunting trip on December 15, 1906, in San Pablo, Nueva Ecija.
  • A.H. Barnes was hunting with J.A. Ryan and three Filipino companions, including Pedro Leonardo.
  • While preparing to leave, Barnes fired his gun twice but encountered difficulty reloading.
  • In an attempt to force a cartridge into the chamber, he pressed the gun against his knee, resulting in an accidental discharge.
  • At the time of the discharge, Leonardo was nearby, unaware of the impending danger.
  • Barnes and his companions rushed to assist Leonardo, who had sustained a fatal gunshot wound to the back of his head.
  • A medical examination confirmed the wound was indeed fatal.
  • On March 27, 1907, the provincial fiscal charged Barnes with reckless negligence.
  • The trial court convicted Barnes, sentencing him to six months of arresto mayor and ordering him to pay P300 to Leonardo's heirs.
  • Barnes subsequently appealed the trial court's decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed the lower court's decision and acquitted A.H. Barnes.
  • The court determined that the act leading to Leonardo's death was involuntary an...(Unlock)

Ratio:

  • The court concluded that the shooting was an involuntary act.
  • For an action to be classified as a crime under the Penal Code, it must be voluntary and accompanied by malice.
  • Barnes did not aim the gun at Leonardo nor did he intend to inflict harm; the discharge was purely accidental.
  • T...continue reading

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