Title
People vs. Tanedo
Case
G.R. No. 5418
Decision Date
Feb 12, 1910
Defendant acquitted of murder; Supreme Court ruled shooting accidental, citing lack of intent, motive, and failure to prove guilt beyond reasonable doubt.

Case Digest (G.R. No. 5418)
Expanded Legal Reasoning Model

Facts:

  • Background and Circumstances of the Incident
    • The defendant, a landowner, along with his laborers, went to work on a malecon (dam) on his property on the morning of January 26, 1909.
    • After setting his laborers to work, he took his shotgun and a few shells with the intention of hunting wild chickens.
    • He crossed a stream to inspect alterations made to the malecon affecting the adjacent rice field, carrying his shotgun with him.
  • Encounter with the Deceased
    • On the other side of the stream, the defendant encountered Feliciano Sanchez—a young man of about 20 years—who had been residing in a small shack with his mother and uncle during the rice-harvesting season.
    • A dispute arose regarding whether the defendant invited Sanchez to hunt wild chickens or vice versa; while the uncle testified to a mutual invitation, the defendant contended that he simply remained under a manga tree engaged in tying something.
    • Despite the contradiction in testimonies, it is clear that the defendant proceeded into the forest with his firearm and the deceased was present at the scene.
  • The Shooting and Subsequent Actions
    • The defendant testified that upon arriving in the designated area—pointed out by Sanchez—the defendant shot at a wild chicken.
    • After firing a single shot, he heard a human cry, later discovering that a man had been wounded by the gunshot.
    • Evidence at the scene included abundant chicken feathers and confirmation of only one gunshot, indicating that the shot intended for a chicken had also fatally injured the deceased.
    • Upon realizing the occurrence, the defendant hurried back to the malecon and initially left his shotgun behind.
    • He then involved his friend and laborer, Bernardino Tagampa, with whom he subsequently went to the location of the wounded man.
  • Handling and Concealment of Evidence
    • The defendant and Tagampa removed the body from the site where it was initially concealed in cogon grass.
    • Later that day, the body was transported a considerable distance (approximately 1,700–1,800 meters) and buried in an old well, where it was covered with straw, earth, and additional burning of straw to further hide evidence of the crime.
    • Although the defendant initially denied any knowledge of the death or the whereabouts of the body, he eventually admitted his participation in the events on trial, giving testimony that was substantially consistent with the known sequence of events.
  • Relationships and Motive
    • There was no evidence of prior animosity between the defendant and the deceased; their relationship was deemed normal with no underlying motive for murder.
    • The only potential basis for the killing appeared to be a sudden, unprovoked quarrel during the hunt—an idea that was invalidated by the fact that both the chicken and the man were struck by the same, single gunshot.

Issues:

  • Determination of Criminal Intent
    • Whether the evidence sufficiently proved that the killing of Feliciano Sanchez was intentional, as required for a conviction of murder.
  • Nature of the Act Committed
    • Whether the defendant’s actions, which took place in the course of a lawful activity (hunting), can be attributed to an accidental misadventure rather than a deliberate act of homicide.
  • Adequacy of the Evidence Against the Defendant
    • Whether the merely circumstantial evidence and the defendant’s concealment and initial denial are enough to overcome the presumption of innocence and establish guilt beyond a reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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