Monday, February 20, 2012

People vs. Palalon

Facts: The crime charged against the accused is homicide. Palalon, the accused, was the foreman on the plantation of Andres Mendiola in Oriental Negros, in charge of a small group of children. The deceased was a ten year old boy who was sitting down resting. The accused reprimanded the boy for slacking around and ordered him to get back to work. The boy answered insolently. Not being able to control himself, the accused struck the boy on the mouth with the back of his hand. On the prosecution side, the testimony was that the boy fell on his back on a tramway rail, with the boy’s nose and mouth bleeding. On the defendant side, the testimony was that the boy did not fall and that no bleeding occurred. The boy continued to work until about the afternoon of the following day, when he was taken sick with fever and went home early that day. Two and a half days after, the boy died. The medical examination found that the body of the deceased had ecchymosis on the right shoulder and on the stomach and that, as a result of the former, there was a congestion of the right lung, which was the principal cause of the death. However, there was no proper autopsy made on the body. The Court of First Instance declared the accused guilty of the crime of homicide. 

Issue: Whether the Court of First Instance erred in deciding that the accused is guilty of the crime of homicide 

Held: No. Accused is acquitted of the crime charged. Decision rendered by the lower court is reversed. 

The Court ruled that the examination of the body took place over twenty-four hours after the death and appeared to have been very incomplete; no incisions were made and the examining physician, a young man of limited experience, admitted that his conclusions were partly based upon the statements of the members of the family of the deceased. The Court believes that the physician merely drew unwarranted conclusions from external appearances which were susceptible of different interpretations. As a result, there was more than reasonable doubt as to the cause of the death of the accused. Consequently, the accused must be acquitted for not being able to prove beyond reasonable doubt the crime charged.

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