CASE No.

William Addenbrook vs. People of the Philippines

GR. No. L-22995, June 29, 1967

Doctrine (Competency of Witnesses; Rule 130 Section 20):

Credibility of witnesses is a question of fact and therefore, not reviewable by the Supreme
Court. The objection to patrolman Guzman’s competency because he was not presented as
an expert witness, nor did he see the incident actually happen, is untenable. What Guzman
testified to are what he saw in his ocular investigation, such as the two (2) sets of bloodstains
and the 15 paces distance between them, that were facts derived from his own perception.

Facts:

The present petition (petition for certiorari) seeks the review of the decision of the Court of
Appeals affirming the conviction by the CFI of Manila for Homicide through Reckless
Imprudence upon the petitioner William Addenbrook y Barker. The petitioner Addenbrook,
while driving a Stanvac Service Van, came into contact with the body of a pedestrian
Wenceslao Risaldo, resulting in his subsequent death. As observed by patrolman Emilio
Guzman in his ocular inspection of the crime scene immediately after the incident happened,
the victim fell and rolled to a distance of fifteen (15) paces, as shown by the two (2) sets of
bloodstains. This testimony of patrolman Guzman had become the basis of conviction of the
petitioner Addenbrook since it was established that he was driving the van in an unreasonable
speed in order for the victim to roll over fifteen (15) paces. This caused the petitioner to file the
present action, questioning the competency of patrolman Guzman as a witness on the reason
that he was not able to personally witness the incident as it happened.

Issue:

Whether or not the non-presence of patrolman Guzman in the accident disqualifies him as a
competent witness.

Ruling:

The Court affirmed the findings of the Court of Appeals, stating that “Credibility of witnesses is
a question of fact and therefore, not reviewable by the Supreme Court. The objection to
patrolman Guzman’s competency because he was not presented as an expert witness, nor did
he see the incident actually happen, is untenable. What Guzman testified to are what he saw
in his ocular investigation, such as the two (2) sets of bloodstains and the 15 paces distance
between them, that were facts derived from his own perception.”. Moreover, other defenses of
the petitioner such as the fact that the victim suddenly appeared and darted across the street
is untenable since the petitioner was still found to be negligent in operating and driving the van
(excessive speed, and he did not blow his horn despite his allegation that his view of the street
is slight obstructed by a parked car).