082. US v.

TANEDO
G.R. No. L-5418 | February 12, 1910 | En Banc | Appeal
THE UNITED STATES, plaintiff-appellee
CECILIO TAÑ EDO, defendant-appellant
MORELAND, J.
Digest by Jadd Dealino

Short Version:
Tañ edo went to work on a dam near his land. He brought a shotgun to hunt wild chickens. He checked out a
nearby stream to see how the dam work would affect the stream. He encountered Feliciano Sanchez, a tenant
on the land. Sanchez was tying something under a manga tree near his shack. Tañ edo asked where wild
chickens could be hunted, and Sanchez directed Tañ edo to a spot near the shack. Tañ edo went there
(according to the prosecution, they hunted together.) In any case, Tañ edo shot and killed a wild chicken, but a
human cry was heard at the same time. It turns out that Sanchez was also shot. Tañ edo returned with a
laborer to hide the body. Tañ edo was charged with Murder. The Tarlac CFI convicted Tañ edo for homicide.
The SC reversed the CFI and acquitted Tañ edo due to a lack of evidence showing that Tañ edo was negligent.

Facts:
 Cecilio Tañ edo is a landowner.
 Together with his laborers, Tañ edo went to work on a dam (malecon) near his land. Tañ edo brought
a shotgun, as he intended to hunt wild chickens so they would have something to eat.
 After an hour with his laborers, Tañ edo went to a stream to see how the alteration of the dam would
affect the stream. On the other side of the stream, Tañ edo met Feliciano Sanchez. Sanchez was a
tenant who lived on the land, together with his mother and uncle. Tañ edo asked the unlce for a good
place to hunt wild chickens. The uncle was resting inside a shack at the time, so Sanchez referred
Tañ edo to a part of the forest near the edge of the shack.
o At this point, there is some variance between the Prosecution and the defense’s version:
 The prosecution asserts that Sanchez and Tañ edo mutually invited each other to go
hunting.
 The defense asserts that Sanchez was busy tying something under a manga tree, a
short distance from the shack.
 Tañ edo went to the place pointed out by Sanchez. Tañ edo shot and killed a wild chicken. However, a
human cry was also heard. Sanchez was also shot.
 Tañ edo returned to his laborers and brought one of them to help him conceal Sanchez’ body.
 Tañ edo was charged with Murder.
 The Tarlac CFI convicted Tañ edo for Homicide, sentencing him to 14y 8m 1d of reclusion temporal.

Issue(s):
Whether Tañ edo is criminally liable for the death of Sanchez. NO.

Dispositive:
ACQUITTED. Costs de oficio.

Reasoning:
1) Tañ edo is not criminally liable for Sanchez’ death because of the insufficiency of the evidence, so
what more likely happened was an accident.
a. The SC notes that there was neither enmity nor unpleasant relations between Tañ edo and
Sanchez, nor any showing of such. Thus, the only reason for a killing to take place is a sudden
quarrel between the two. This in turn is negated by the fact that only one shot was fired,
which killed both a man and a chicken.
b. The SC cites Philippine laws and American cases, to the effect that based on the presumption
of innocence and the need for proof beyond reasonable doubt, the SC believes Tañ edo’s
version that an accident happened. There was no showing of negligence on the part of
Tañ edo.
 i. Article 1 of the Penal Code: “Crimes or misdemeanors are voluntary acts and
omissions punished by law. Acts and omissions punished by law are always
presumed to be voluntary unless the contrary shall appear.”
ii. Art. 8, subdivision 8 of the Penal Code says “He who, while performing a legal act
with due care, causes some injury by mere accident without liability or intention of
causing it.”
iii. Sec. 57 of the Code of Criminal Procedure provides: “A defendant in a criminal action
shall be presumed innocent until the contrary is proved, and in case of reasonable
doubt that his guilty is satisfactorily shown he shall be entitled to an acquittal.”
iv. The American doctrine is the same, that there is no criminal liability where a life
is taken by misfortune or accident while in the performance of a lawful act
executed with due care and without intention of doing harm. (Citing Tidwell v.
State, etc.)
1. Citing Tidwell v. State:
a. An accused is not required to prove his defense of accidental
killing.
i. This is because there is a denial, the burden is on the State
to show that it was intentional.
ii. If there is reasonable doubt as to the killing, an acquittal
prevails.
2. Citing State v. Legg:
a. The prosecution must negate, beyond reasonable doubt, a plea of
“misadventure.” Such a plea is a denial of criminal intent, which is
an essential element in criminal homicide.
v. In this case:
1. There is insufficient evidence to convict Tañ edo.
a. There is no evidence of negligence on the part of Tañ edo;
b. Tañ edo was engaged in the commission of a lawful act (hunting);
c. There is no evidence that Tañ edo intended to kill Sanchez.

Voting of Justices
Arellano, C.J., Torres, Mapa, and Johnson, JJ., concur.

Separate Opinion(s): N/A