G.R. No. L-10563; March 2, 1916
THE UNITED STATES, plaintiff-appellee, vs. ANTONIO BONIFACIO, defendant-appellant.

FACTS:
On October 31, 1913, in Batangas, the accused Antonio Bonifacio, a railroad engineer, was operating a freight train when he saw Eligio Castillo, a deaf-mute, walking near the railroad track. The train had just rounded a curve, and Castillo was about 175 meters ahead. Bonifacio blew the whistle twice as a warning. When Castillo did not respond and attempted to cross the track, Bonifacio applied the brakes but failed to stop in time, resulting in Castillo’s death. The train was running at a speed of 35 kilometers per hour, the maximum allowed for freight trains under railroad regulations. The track had a downward slope from the curve to the accident site. The trial court convicted Bonifacio of homicide through simple negligence, finding that the train might have exceeded the speed limit due to the decline.

ISSUE:
Whether the accused is criminally liable for homicide through reckless or simple negligence.

RULING:
The Supreme Court REVERSED the trial court’s decision and ACQUITTED the accused. The Court held that:
1. The death resulted from an unavoidable accident, attributable solely to the negligence of the deceased, who was a deaf-mute unaware of the approaching train.
2. An engine driver is not obligated to stop or slow down upon seeing an adult pedestrian near the track, absent signs that the person cannot or will not avoid danger. The driver’s duty is to give adequate warning, which Bonifacio did by blowing the whistle.
3. The evidence did not prove beyond reasonable doubt that the train exceeded the speed limit. Even if it did, any slight excess speed had no causal connection to the accident, as the accident would have occurred regardless due to the deceased’s conduct.
4. For liability under Article 568 of the Penal Code (simple negligence with violation of a regulation), the violation must be the proximate cause of the injury. Here, no such causal link was established.
Thus, the accused incurred no criminal liability.