GR L 5097; (February, 1910) (Digest)
G.R. No. L-5097
THE UNITED STATES, plaintiff-appellee, vs. PEDRO EDUARDO, defendant-appellant.
February 10, 1910
FACTS:
Pedro Eduardo, master of the launch San Gabriel (licensed to carry 30 passengers and 11 crew), was accused of reckless negligence causing the death of Erisberta Garrido and others. On July 16, 1908, despite clear indications of extreme danger, Eduardo sailed the San Gabriel from the Pasig River into Manila Bay. The launch was severely overloaded with approximately 100 passengers (more than three times its capacity) and excessive freight. A policeman had warned against taking more freight, the owner’s son advised Eduardo not to leave the river due to bad weather, and a second storm signal was prominently displayed in Manila, which Eduardo knew. Furthermore, the launch’s hull was potentially weakened from a recent collision. Disregarding all these warnings, Eduardo proceeded with the voyage. While in Manila Bay, the San Gabriel foundered during a severe storm, resulting in the drowning of Erisberta Garrido and others. The acts of negligence occurred in Manila harbor, but the foundering and deaths occurred in Manila Bay, outside the harbor limits. The lower court found Eduardo guilty of reckless negligence under Article 568 of the Penal Code and sentenced him to one year and six months of presidio correccional. Eduardo appealed, questioning the sufficiency of the evidence.
ISSUE:
Whether the evidence presented was sufficient to prove Pedro Eduardo’s guilt of reckless negligence causing death under Article 568 of the Penal Code.
RULING:
Yes. The Supreme Court affirmed the lower court’s decision, holding that the evidence showed, beyond reasonable doubt, that Pedro Eduardo was guilty of a violation of Article 568 of the Penal Code. The Court found that Eduardo, through his reckless negligence and without due regard for the safety of Erisberta Garrido and the other passengers, raised anchor and sailed the severely overloaded launch out of the Pasig River into Manila Bay in the face of a severe storm. This negligence and overloading directly caused the launch to founder and Erisberta Garrido and others to drown. The penalty imposed by the lower court was therefore affirmed.