People v. Azajar
REITERATIONFacts
The Antecedents: On August 9, 1913, Catalino Delmo was engaged in cutting grass on the tracks of the Manila Railroad Company near Santa Rosa station, Province of Laguna. He was working alone, approximately seven telegraph poles away from his five or six companions. The defendant, Mariano Azajar, was the locomotive engineer of a train traveling from Manila towards Santa Rosa station. The train, managed by the defendant, ran over Catalino Delmo, causing his instantaneous death. Procedural History: The defendant was charged with homicide by reckless negligence. The trial court found him guilty, sentencing him to imprisonment, indemnity to the deceased's family, and costs. The defendant appealed the judgment. The Petition: The defendant assigned errors concerning the lower court's belief in prosecution witnesses, its weighing of evidence, its failure to hold reasonable doubt, and its failure to find that the sole cause of the accident was the deceased's own imprudence.
Issue(s)
Whether the defendant, as a locomotive engineer, was guilty of criminal negligence and imprudence in the management of his train at the time of the accident. Whether the sole cause of the accident was the imprudence of the deceased, Catalino Delmo.
Ruling
The Supreme Court reversed the judgment of the lower court, ordered the complaint against the defendant dismissed, and decreed his discharge from custody, with costs de officio.
Ratio Decidendi
On whether the defendant was guilty of criminal negligence and imprudence: The Court found that the engineer had a right to assume that Catalino Delmo, a track worker, would exercise reasonable care, be on the lookout for approaching trains, and heed signals. While the foreman testified that the engineer failed to give alarm or slow down, the defendant testified he used every means to warn Delmo and slow the train. Passengers on the train corroborated the defendant's claim of repeated signals. The proof showed Delmo left the track after repeated signals but returned to retrieve his hat, at which point it was impossible for the engineer to avoid the impact. The Court cited established rules that persons on a railroad track are bound to be diligent and keep a lookout, especially railroad employees. The engineer exercised every precaution required, and Delmo's sudden and unexpected return to the track, without justifiable reason, at a moment when avoidance was impossible, was the proximate cause of his death. Therefore, the defendant was guilty of no negligence, willful, intentional, or otherwise, sufficient to justify his conviction. On whether the sole cause of the accident was the deceased's imprudence: The evidence indicated that Delmo was working alone, some distance from his companions, and continued working despite hearing and seeing the approaching train (as evidenced by his leaving the track). His companions, who were further away, heard the train. The foreman's testimony that he ran towards the train with a red flag and called to the engineer, while making no attempt to warn Delmo, was noted as strange conduct. The defendant's testimony, corroborated by passengers, was that he gave repeated signals and slowed the train. Delmo left the track but returned for his hat, an act that was not contemplated or foreseen by the defendant and occurred when it was impossible to avoid the impact. The Court concluded that Delmo's own imprudence in returning to the track without justifiable reason, when it was too late for the engineer to avoid the collision, was the sole cause of the accident.
Main Doctrine
An engineer managing a train has the right to assume that adult persons on the track, especially workmen regularly employed thereon, will exercise reasonable care, be on the lookout for approaching trains, take due notice of signals, and leave the track in ample time to avoid injury. The engineer is not obliged to stop his train immediately upon the failure of a track worker to obey signals, but may assume the worker possesses all faculties and will act in ample time to avoid danger. If the worker leaves the track but returns unexpectedly to retrieve an item, and the engineer cannot avoid the impact, the engineer may not be guilty of criminal negligence.