G.R. No. L-22995 June 29, 1967
William Addenbrook y Barker, petitioner, vs. People of the Philippines, respondent.

FACTS

The petitioner, William Addenbrook y Barker, was convicted of homicide through reckless imprudence by the Court of First Instance of Manila, a conviction affirmed by the Court of Appeals. The incident occurred around 3:15 PM on January 9, 1960, along Marquez de Comillas Street in Manila. Addenbrook was driving a Stanvac Service Truck southward when its front bumper came into contact with pedestrian Wenceslao Risaldo in front of House No. 1010. Risaldo fell, was taken to the hospital, and was dead on arrival, having sustained multiple injuries including a skull fracture. Patrolman Emilio Guzman’s ocular investigation immediately after the incident revealed two sets of bloodstains fifteen paces apart, indicating the victim rolled that distance upon impact. The appellate court found it difficult to believe the truck was traveling at a slow, reasonable speed. It further noted that the accused’s view was partly blocked by a parked car, from behind which the deceased allegedly tried to cross, and that the accused did not blow his horn despite this visual obstruction. The Court of Appeals concluded the accused failed to observe the reasonable care required of a driver.

ISSUE

Whether the Court of Appeals erred in affirming the conviction for homicide through reckless imprudence based on its factual findings regarding the petitioner’s negligence, specifically his excessive speed and failure to exercise due care.

RULING

The Supreme Court affirmed the decision of the Court of Appeals. The Court held that the credibility of witnesses and the factual findings of the lower courts, including the assessment of patrolman Guzman’s testimony regarding the bloodstains and the distance the victim was thrown, are not reviewable by the Supreme Court as they are questions of fact. The Court found no merit in the objection to patrolman Guzman’s competency, as he testified to facts derived from his own perception during his ocular investigation. The Court upheld the lower courts’ rejection of the petitioner’s claim that the victim suddenly darted from behind a parked car, noting the lack of corroboration and the improbability that a grown man would ignore the danger of an oncoming vehicle. Furthermore, the Court ruled that even if the victim did suddenly dart into the path of the truck, this would not excuse the driver if the truck was being driven at an unreasonable or excessive speed under the circumstances, citing American jurisprudence. The emergency rule was deemed inapplicable as any emergency was of the driver’s own making due to his excessive speed. The other assigned errors raised questions of fact and credibility beyond the Court’s scope of review. The conviction was affirmed, with costs against the petitioner.