People v. Vallados
REITERATIONFacts
The Antecedents: The defendant Paulino Vallados fired upon Francisco Calvo and Placido Echanes, who were unarmed and on a hunting expedition for small birds. The shot resulted in the wounding of Calvo and the death of Echanes. The defendants, who were watchmen on an estate, claimed they believed the approaching persons were robbers. The court found that Calvo and Echanes made no attack and were not attempting to steal the palay being guarded. Procedural History: The court below acquitted the defendant Nicolas Villeta. The widow of Placido Echanes appealed the acquittal of Nicolas Villeta. The Petition: Paulino Vallados was the defendant-appellant. The complainant-appellee was the United States.
Issue(s)
Whether the defendant Paulino Vallados is guilty of homicide with lesiones. Whether the appeal of the widow of Placido Echanes from the acquittal of Nicolas Villeta should be dismissed.
Ruling
The judgment of the court below is reversed. The defendant, Paulino Vallados, is convicted of the crime of homicide with lesiones and is sentenced to ten years of prision mayor, with the costs of this instance and one-half of the costs of the court below against him. The appeal of the widow of Placido Echanes is dismissed.
Ratio Decidendi
On whether the defendant Paulino Vallados is guilty of homicide with lesiones: The Court found that the testimony of the Government's witnesses was more credible than that of the defendants and their witnesses. It was established that Francisco Calvo and Placido Echanes were unarmed and engaged in a hunting expedition for small birds when they were fired upon by the defendant Paulino Vallados. The shot resulted in the wounding of Calvo and the death of Echanes. The Court explicitly stated that Calvo and Echanes made no attack upon the defendants and were not attempting to steal the palay that the defendants were guarding. Despite the defendants' belief that the victims were robbers, the Court held that the offense committed constituted the crime of homicide with lesiones. In favor of the appellant, the Court took into consideration paragraph 7 of article 9 and article 11 of the Penal Code. Applying article 81, paragraph 5, the penalty was fixed at ten years of prision mayor. On whether the appeal of the widow of Placido Echanes from the acquittal of Nicolas Villeta should be dismissed: The Court dismissed the appeal filed by the widow of Placido Echanes concerning the acquittal of Nicolas Villeta. This dismissal was based on the decision of the United States Supreme Court in the case of Kepner vs. the United States. The principle established in Kepner likely pertains to double jeopardy or the finality of acquittals, preventing further prosecution or appeal of an acquitted co-defendant under specific circumstances.
Main Doctrine
Even if the accused believed the victims were robbers, the offense committed is homicide with lesiones, with the penalty fixed considering mitigating circumstances under the Penal Code.