GR 25785; (February, 1981) (Digest)
G.R. No. L-25785 February 26, 1981
SATURNINO BAYASEN, petitioner, vs. COURT OF APPEALS, respondent.
FACTS
Petitioner Saturnino Bayasen, a rural health physician, was charged with Homicide thru Reckless Imprudence. The information alleged that on August 15, 1963, in Sagada, Mountain Province, he drove a jeep in a negligent manner, causing it to fall over a precipice and resulting in the death of passenger Elena Awichen. After trial, the Court of First Instance convicted him. The Court of Appeals affirmed the conviction with modifications, increasing the indemnity and adjusting the penalty. The appellate court found that the proximate cause of the accident was Bayasen’s “negligence in driving at an unreasonable speed” on a narrow and slippery road, which caused him to lose control when the jeep skidded.
The prosecution’s star witness, fellow passenger Dolores Balcita, testified that Bayasen was driving at a “moderate speed” just before the accident and explicitly stated she did not know what caused the jeep to fall. She felt no bump or jolt. Bayasen testified that while driving cautiously, the rear wheels of the jeep suddenly skidded on the slippery road. To avoid the embankment, he steered left, but the jeep continued, hit a pine tree, and fell.
ISSUE
Whether the Court of Appeals erred in convicting the petitioner based on a finding of negligence, specifically “driving at an unreasonable speed,” which is allegedly contrary to the evidence.
RULING
Yes. The Supreme Court reversed the Court of Appeals and acquitted the petitioner. The legal logic centers on the insufficiency of evidence to prove negligence beyond reasonable doubt. The finding of “unreasonable speed” as the proximate cause is openly contrary to the prosecution’s own evidence. The sole eyewitness testified to moderate speed and no knowledge of the cause, providing no factual basis for the appellate court’s conclusion.
Crucially, the evidence established that the immediate cause was the skidding of the rear wheels on a slippery road. Skidding, by itself, is not conclusive proof of negligence; it can occur without fault as an unforeseen event. Since the prosecution failed to present legally sufficient proof that the skidding was attributable to the petitioner’s negligent operation of the vehicle, his guilt was not established beyond a reasonable doubt. The presumption of innocence must prevail. Therefore, the decision of the Court of Appeals was set aside.