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 Summary (G.R. No. L-22995)

Incident and Initial Findings

The Court of Appeals found that while driving a Stanvac Service Truck, Addenbrook's vehicle made contact with Risaldo, causing the latter to sustain serious injuries. Following the impact, Risaldo was transported to the Philippine General Hospital but succumbed to his injuries shortly after arrival. The appellant's vehicle was found to have left a distinct trail of bloodstains at the scene, indicating the severity of the incident.

Evidence and Witness Testimony

The Court considered the testimony of Patrolman Emilio Guzman, who conducted an ocular investigation immediately after the accident. His observations included two sets of bloodstains and the distance of fifteen paces that Risaldo rolled after the collision. The credibility of Guzman's account was noted, emphasizing his firsthand observations rather than expert knowledge. Hence, the Court found no basis for questioning his competency as a witness, dismissing appellant's claims regarding Sudden Emergency as unsupported.

Legal Standards and Recklessness

The Court reaffirmed the legal standard regarding a driver's duty to operate their vehicle with reasonable care. It concluded that Addenbrook failed to fulfill this duty due to operating at a speed that was neither slow nor reasonable under the circumstances. The presence of a parked car that partially obstructed his view, coupled with his failure to sound the horn, led to the conclusion that Addenbrook did not exercise the caution expected of a motor vehicle operator.

Affirmation of the Conviction

The appellate court found insufficient evidence to support Addenbrook's assertion that Risaldo had suddenly appeared from behind the parked vehicle. The victim's age and presumed awareness of the oncoming vehicle negated the argument of unforesee

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