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18. Picart v. Smith Jr., G.R. No. L-12219, March 15, 1918

Facts:
The incident occurred on December 12, 1912, on Carlatan Bridge in La Union. Amado
Picart, the plaintiff, was riding his pony on the bridge when Frank Smith, Jr., the
defendant, approached in an automobile at a speed of 10-12 miles per hour.
Smith honked the horn to signal his approach, giving successive warnings. Picart,
perturbed by the situation, pulled his pony toward the right railing of the bridge instead
of moving to the left side.
Despite perceiving the horseman's presence, Smith continued driving toward the center
of the bridge, assuming Picart would move to the other side. When it became clear
Picart wouldn't move, Smith attempted to veer right, but the automobile struck the
pony's hind leg, causing it to fall and fatally injuring the horse. Picart suffered injuries as
well.

Issue:
Whether Frank Smith's actions constituted negligence and if he should be held liable for
the damages caused to Amado Picart and his horse.

Decision:
The court applied the standard of conduct expected from a prudent person in a given
situation. Smith should have foreseen the risk and adjusted his driving to avoid the
collision. Negligence was established based on Smith's failure to take precautions, even
after realizing the imminent danger to the horse and rider.
The Supreme Court found Frank Smith liable for negligence. Despite Picart's initial
positioning on the wrong side of the road, Smith failed in his duty to prevent harm once
he realized Picart wouldn't move. Smith's actions, continuing toward the horse without
taking precautions, were negligent.
The court referred to a prior case (Rkes vs. Atlantic, Gulf and Pacific Co.) where
contributory negligence did not bar recovery but could reduce the damages awarded.
However, in the present case, Smith's immediate negligence was deemed the primary
cause of the accident. The judgment of the lower court absolving Frank Smith from
liability was reversed. Amado Picart was awarded ₱200 for damages, covering the
horse's value, Picart's medical expenses, and other losses. Other damages claimed by
Picart were deemed remote and not recoverable.

17. Calimutan v. People, G.R. No. 152133, February 9, 2006

Facts:
Petitioner Calimutan filed a Petition for Review on Certiorari to reverse the convictions
by the RTC and Court of Appeals, dated 19 November 1998 and 29 August 2001
respectively, for homicide.
The victim, Cantre, died, and conflicting autopsy reports arose: one stating food
poisoning and the other citing traumatic abdominal injury.

Issues:
Conflicting Autopsy Reports: The main issue was the contradictory findings in the
autopsy reports on the cause of the victim's death.
Reasonable Doubt: Whether the conflicting reports raised reasonable doubt regarding
Calimutan's culpability for the victim's death.

Ruling:
The Court found Calimutan guilty beyond reasonable doubt of reckless imprudence
resulting in homicide.
Despite acknowledging Calimutan's lack of intent to kill, his action of throwing a stone
that caused the victim's death was deemed reckless imprudence.
Calimutan was sentenced to imprisonment for a minimum of 4 months of arresto mayor
to a maximum of two years and one day of prision correccional.
He was also ordered to pay ₱50,000.00 as civil indemnity for the victim's death and an
additional ₱50,000.00 as moral damages to the victim's heirs.
The court upheld the conviction based on reckless imprudence, ruling that Calimutan's
act of throwing a stone led to the victim's death, even without intent to cause harm.
16. People v. Fausta Gonzales, et al., G.R. No. 80762, March 19, 1990 (183 SCRA
309)
Facts:
The murder of Lloyd Peñacerrada in 1981 in Ajuy, Iloilo, Philippines. Fausta Gonzales
and her husband Augusto Gonzales were initially accused of the crime. Later, Custodio
Gonzales, Sr., Custodio Gonzales, Jr., Nerio Gonzales, and Rogelio Lanida were also
implicated.
The prosecution's main witness, Jose Huntoria, alleged that he witnessed the accused
attacking and killing Peñacerrada. However, Huntoria admitted during cross-
examination that he couldn't identify who specifically performed the stabbing or hacking
due to the rapid movement of the assailants.
The investigation conducted by police authorities was deemed inadequate and lacking.
Patrolman Centeno made errors in his sworn statements regarding the date of the
crime. The investigation by other authorities, including the PC investigators, also raised
doubts as they mentioned four unnamed persons apart from the accused spouses
involved in the killing.
Dr. Rojas, who conducted the autopsy on Peñacerrada's body, confirmed 16 wounds,
with only five being fatal. He stated that it was possible multiple weapons caused the
wounds, but admitted that one blade might have caused them all.

Issue:
The primary issue in the case involving Custodio Gonzales, Sr. revolves around the
sufficiency of evidence and the credibility of the prosecution's witness testimony. The
key issue centers on whether there was enough substantial evidence to prove Custodio
Gonzales, Sr.'s guilt beyond a reasonable doubt for the murder of Lloyd Peñacerrada.
The case hinged on the testimony of Jose Huntoria, the prosecution's main witness,
who alleged witnessing the attack but couldn't identify the specific individual responsible
for the fatal act due to the rapid movement of the assailants.
The court had to evaluate the credibility of the witness, the inconsistencies in his
testimony, the lack of specificity regarding the accused's involvement, and the absence
of concrete evidence linking Custodio Gonzales, Sr. directly to the murder. The issue
was whether the evidence presented was adequate and reliable enough to establish
Custodio Gonzales, Sr.'s guilt in committing the crime beyond a reasonable doubt.

Ruling:
The Court of Appeals convicted Custodio Gonzales, Sr. based on Huntoria's testimony.
However, the Supreme Court reviewed the case, highlighting the lack of specificity in
Huntoria's testimony. Huntoria's eight-month delay in reporting the incident raised
doubts about his credibility, especially since he was the victim's tenant and stood to
benefit from testifying.

The Supreme Court found the prosecution's evidence insufficient. It concluded that
there was no specific act attributed to Custodio Gonzales, Sr. that caused
Peñacerrada's death. The lack of evidence to prove conspiracy and the inconsistencies
in Huntoria's testimony led the Court to rule in favor of Custodio Gonzales, Sr. The
conviction was overturned, and Custodio Gonzales, Sr. was acquitted due to insufficient
evidence to establish guilt beyond reasonable doubt.

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