QR Link

Title
People vs Pineda

Case Ponente Decision Date

G.R. No. L-12858 MALCOLM, J Jan 22, 1918

A registered pharmacist in the Philippines is found guilty of violating the Pharmacy Law after
mistakenly selling a poison instead of the requested drug, resulting in the death of two horses,
highlighting the druggist's duty to exercise care and skill in their profession.

Case Digest (G.R. No. L-12858)

Facts:
The case of U.S. v. Pineda involves Santiago Pineda, a registered pharmacist in the
Philippines, who was found guilty of violating the Pharmacy Law. The incident
occurred when Pineda mistakenly sold barium chlorate, a poison, instead of potassium
chlorate, a requested drug, which resulted in the death of two horses. The prescription
was given by Feliciano Santos, who had previously used the same prescription for his
horses with good results. Upon analyzing the packages, it was discovered that the
drugs sold by Pineda were indeed barium chlorate instead of potassium chlorate. The
chemists who conducted the analysis also purchased potassium chlorate from Pineda's
drug store, which was later found to be barium chlorate as well.

Issue:
The main issue raised in the case is whether the testimony of the chemists should have
been admitted as evidence.

Ruling:
The court ruled that the testimony of the chemists was admissible as evidence.

Ratio:
The court justified the admissibility of the chemists' testimony by stating that it was
necessary to demonstrate Pineda's motive and negligence. The court emphasized that
the profession of pharmacy requires a high degree of care and skill, and the druggist
has a duty to prevent harm to those who rely on their expertise. In this case, Pineda's
mistake in selling the wrong drug resulted in the death of two horses. The court
rejected the application of the rule of caveat emptor, which means "let the buyer
beware," in the purchase and sale of drugs. Instead, the court held that the druggist
warrants the delivery of the drug requested. Therefore, Pineda was held accountable
for his negligence in selling the wrong drug.

Furthermore, the court interpreted the word "fraudulent" in the Pharmacy Law to mean
the giving of a false name to the drug asked for, rather than strict fraud. This
interpretation supports the notion that Pineda's mistake in selling the wrong drug was
a violation of the Pharmacy Law. The court concluded that Pineda was guilty of
violating the Pharmacy Law and upheld the lower court's decision. As a result, Pineda
was sentenced to pay a fine of P100 and the costs of the case.