People v. Eulo & People v.

Bonilla
| 30 October 1984 | Chief Judge Cooke
Topic: Art. 249 Homicide
Aggy

Case Summary:
TL;DR: The two cases are consolidated appeals seeking the reversal of the conviction of homicide. In both
cases, the victims were both diagnosed to have brain damage which required mechanical and artificial
assistance for their breathing and heartbeat to continue. The defendants, Eulo and Bonilla, appealed their
cases and argued that they must be relieved of criminal liability since the victims were pronounced dead and
had their organs removed even though their heartbeat and breathing were being continued by artificial means;
and it was the cessation of the lungs and heart that constituted death. The Court affirmed the conviction and
held that common law definition of death recognizes that the cessation of the brain functions to the point that
it requires artificial assistance for the continuance of a person’s breathing or heartbeat.

Doctrine:
Death, in law, is the opposite of life. It occurs when a determination has been made in accordance to accepted
medical standards that a person has suffered an irreversible cessation of heartbeat and respiration, or, when
such functions are solely maintained thru artificial means due to the irreversible damage to the brain. In such
case, no life is present in that body.

Facts:

(I’ll put this lang just in case)

Cerebrum (higher brain) – part of the brain which controls cognitive functions
Cerebellum – controls motor coordination
Brain stem (lower brain) – controls reflexive or spontaneous functions (like breathing)

PEOPLE V. EULO
- Eulo and his girlfriend attended a volunteer firemen’s fair in Kings Park, Suffolk County. They had an
argument due to Eulo’s jealousy; and when things got heated, he shot her in the head with his
unregistered handgun.

PEOPLE V. BONILLA
- A New York City police officer found a man lying face-up on a Brooklyn St. with a bullet wound to the
head.

IN BOTH CASES,
- The victims were rushed to the hospital. Various tests were made to evaluate the damage done to
their brain. A mechanical respirator was connected to them to enable them to continue breathing.
The doctors diagnosed that the victims’ entire brain had irreversibly ceased to function.
- The victims’ organs were removed for transfer even before the respirator was removed. Once the
mechanical respirator was disconnected, the victims’ breathing and heartbeat ceased.
- Both defendants were convicted of manslaughter.
- The defendants maintained that the jury should have been instructed of the criteria applied in
recognizing death—which is the cessation of the lungs and heart, and the fact that the victims’
breathing and heartbeat continued despite the removal or their organs and the pronouncement of
their death, challenges their conviction of homicide.
Issue/s:
W/N the removal of the organs of the victims and the pronouncement of their deaths notwithstanding the
continuation of their breathing and heartbeat through artificial means relieve the defendants of
their criminal liability? – NO.

Holding:
The Court ruled that although death is generally regarded as the cessation of the function of the heart
and the lungs, this does not mean that the recognition of a brain-based criteria for death is inconsistent
with the Legislature’s concept of death. The brain-based criteria is supplemental to the traditional criteria,
each describing the same phenomenon of death. (In essence, patay na talaga sila since wala na
nagfufunction)

Medical advancements have developed which enabled the maintenance of the operation of one’s heart
and lungs, for a limited time, to substitute the failure of the brain to function. Further, breathing and
heartbeat are not independent indication of life. They are part of an integration of functions in which the
brain is dominant.

The defendants, then, must be convicted as their offense was the cause of the cessations of the victims’
brain to function.

TLDR: So basically, the court is saying that the victims were still breathing and their hearts were still
beating despite the pronouncement of their death and removal of their organs BECAUSE OF ARTIFICIAL
MEANS. Their brains ceased to function. They would have been dead if it were not for the machine. Their
deaths were pronounced before the machine was disconnected because it was to preserve their organs
while they were being removed because if a person’s vital functions cease, their organs quickly
deteriorate and lose their transplant value (hindi na fresh ganun).

Ruling:
Order of the Appellate Division is AFFIRMED.

Relevant Provisions: