People v. Tayongtong
REITERATIONFacts
The Antecedents: On January 19, 1911, Severino Resume was painting telephone poles along the highway between Jaro and Iloilo. He was killed when an automobile driven by the defendant, Policarpo Tayongtong, ran over him. The highway was straight, wide, and in good condition. The telephone pole was located about 2 feet into the grass at the side of the highway, with a pathway between it and the beaten portion. The automobile was a large passenger vehicle with racks extending beyond the wheels for carrying parcels. Procedural History: The defendant was convicted of homicide by negligence (homicidio por imprudencia temeraria) by the trial court. He appealed the conviction. The Petition: The defendant appealed, asserting that the evidence presented did not warrant his conviction.
Issue(s)
Whether Policarpio Tayongtong is guilty of homicide by negligence (homicidio por imprudencia temeraria) based on the conflicting accounts of the accident.
Ruling
The judgment of conviction is reversed, and the accused is acquitted.
Ratio Decidendi
On Issue 1: The Supreme Court held that the evidence was insufficient to sustain a conviction because the prosecution's theory was unreasonable and physically improbable. The Court observed that for Tayongtong's vehicle to have hit the victim while he was standing behind a telephone pole—without the vehicle's protruding baggage racks first striking the pole itself—was a physical impossibility. Furthermore, the fact that the victim’s body was found in the traveled portion of the highway, rather than in the drainage ditch, strongly supported the defense’s version that the victim had run into the path of the car. The Court noted that Pablo Tayson’s credibility was severely impaired by his conflicting statements regarding whether he covered his eyes to avoid dust at the time of the accident. In contrast, the Court found Tayongtong's testimony—that he was driving at a moderate speed and the victim suddenly darted across the road—to be consistent with common sense and common experience. Applying the principle in U.S. v. Reyes, the Court clarified that while contributory negligence is not a defense when the driver is negligent, the driver cannot be held liable if the death is due solely to the victim’s own negligence and the driver was not negligent. Since Tayongtong was handling the vehicle in a usual and ordinary manner and could not have anticipated the victim's sudden move, he was not guilty of any criminal negligence.
Main Doctrine
Where death is due to the negligence of the decedent himself and not to the negligence of the driver of the automobile, the latter cannot be held for homicide. In such cases, the death of the deceased was entirely due to his own negligence, and there being no negligence on the part of the driver, he is not responsible, no matter what the result of the accident may have been.