Case Digest (G.R. No. 7255)
Facts:
United States v. Teodoro Juanillo, G.R. No. 7255. October 03, 1912, the Supreme Court, Trent, J., writing for the Court (Arellano, C.J., Torres, Mapa, Johnson, and Carson, JJ., concurring). The appeal arose from a conviction by the Court of First Instance at Iloilo (Judge J. S. Powell) sentencing Teodoro Juanillo (defendant and appellant) to one year and one day of presidio correccional, P1,000 civil indemnity to the heirs of Ponciano Leal, subsidiary imprisonment in case of insolvency, and costs for the crime of negligent homicide (imprudencia temeraria con homicidio).On April 23, 1911, at about 4 p.m., Ponciano Leal was struck and fatally injured by an automobile on the public highway between Pavia and Santa Barbara, Iloilo. It was admitted that Juanillo was the automobile's chauffeur. The prosecution alleged reckless driving caused Leal’s death; the defense maintained the incident was a pure accident. The criminal information was tried in the Court of First Instance where the prosecution offered four witnesses (including Pedro Latoja, Juan Labrila, Nicolas Agraviado, and Petronio Leal) who testified that the men were walking abreast, that Latoja heard a noise and called out, jumped left and collided with Labrila, and that when they looked back Leal was down in the road; none saw the precise moment of impact.
The defense produced six witnesses: five passengers of the automobile (Henry J. Becker, Charles C. Dean, W. H. Rimmer, Garret A. Harwood, Joseph Miller) and the appellant. Their testimony described seeing the natives on the road, use of horn, exhaust and brakes, varying accounts of distance and speed (estimates ranged from about 6–20 miles per hour), and that Leal suddenly dashed across the road and was struck by the left fender or lamp. Juanillo testified he cut power and sounded the horn when about 80–100 brazas away, was going 15–20 miles per hour then, slowed to 6–8 miles per hour when the dash occurred, applied brakes but could not stop immediately, and ran 3–4 brazas after impact.
The trial court found Juanillo guilty of negligent homicide. On appeal to the Supreme Court (this appeal), the primary factual conflicts addressed were credibility of rural witnesses versus occupants of the automobile, the precise speed, braking, and distances, and whether the driver's conduct amounted to "reckless imprudence" under Article 568 of the Penal Code. The Supreme Court reviewed the testimony, weighed credibility, and addressed two principal legal contentions advanced by defense couns...(Pro-only)
Issues:
- Did the evidence show reckless imprudence under Article 568 of the Penal Code amounting to negligent homicide as charged?
- Did the trial court err in (a) taking judicial notice of the stopping power of automobiles and (b) its legal conception that automobile drivers must refrain from running at a speed greater than they can stop wh...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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