Commonwealth v. Spohn

35 Pa. D. & C. 400, 1938 Pa. Dist. & Cnty. Dec. LEXIS 71
CourtBerks County Court of Quarter Sessions
DecidedJuly 28, 1938
Docketno. 247
StatusPublished

This text of 35 Pa. D. & C. 400 (Commonwealth v. Spohn) is published on Counsel Stack Legal Research, covering Berks County Court of Quarter Sessions primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Spohn, 35 Pa. D. & C. 400, 1938 Pa. Dist. & Cnty. Dec. LEXIS 71 (Pa. Super. Ct. 1938).

Opinion

Shanaman, J.,

Defendant was indicted for simple assault and battery. At the trial he testified that he had intentionally struck the blow, and he described attendant circumstances which, if found by the jury to have existed, entitled him to commit the battery as a lawful act of self-defense. The case was tried on this theory. The trial judge charged that the burden was on defendant to show by the fair weight of the evidence that the circumstances warranted a reasonable man in striking the prosecutor, as an act of reasonable self-defense. The court refused defendant’s request to charge that the burden was on the Commonwealth to show defendant’s guilt beyond a reasonable doubt. Defendant seeks a retrial because of this alleged error in the charge. The precise point appears never to have been ruled in an indictment for assault and battery. In Commonwealth v. Di Silvestro (No. 1), 31 Pa. Superior Ct. 537, the court in a prosecution for libel held that, since defendant at the trial admitted the publication by him of matter which the law declares malicious, there was no other point of fact growing out of the evidence which could raise a reasonable doubt, and that therefore the court was justified in refusing to charge concerning reasonable doubt. This case, involving a writing, as the gravamen of the charge, represents perhaps the limit beyond which a refusal to charge on reasonable doubt would not be justified.

In Commonwealth v. Brown, 17 Dist. R. 89, involving murder, the court said:

“On such a charge the Commonwealth must make out its own case beyond a reasonable doubt, and to do this it [402]*402must show that the offence was committed by the defendant ; that is, a killing purposely, not the result of an accident. In a case like the present, where this has been shown by the Commonwealth and admitted by the defendant, the rule as to the reasonable doubt has been fully complied with and no longer applies”: p. 90.
“. . . in a case like the present, where the defendant admits the killing and seeks to excuse it, the only question left for trial is as to the validity of the excuse. Under such circumstances the case is practically in the same position as if the defendant pleaded in confession and avoidance, and it is for him to point to a fair preponderance of evidence to sustain his defence”: p. 92.

In the present case, we charged the jury in accordance with the principle just cited. After mature consideration we are of opinion that this was error.

We remark that the opinion in Commonwealth v. Brown, supra, while persuasive and highly respectable, is not obligatory upon us as authority. In Commonwealth v. Troup, 302 Pa. 246, involving the offense of murder, the Supreme Court said (p. 252) :

“Defendant attempted to set up an affirmative excuse, and the burden was therefore on him to establish it by the preponderance of the evidence, to be effective and justify a verdict exonerating him from responsibility. . . . Ordinarily, a defendant is entitled to an acquittal if an honest question of his guilt is engendered from any or all the evidence offered. . . . Such must arise out of evidence essential to the Commonwealth’s case, whether bearing on some isolated point or the whole of the evidence. . . . Where, however, the right to a verdict rests on defendant’s establishing by affirmative and satisfying proof some fact, it is not sufficient for him to merely raise a doubt as to its existence.”

It seems clear that the doubt here stated by the Supreme Court to be insufficient to acquit is a doubt as to the existence of facts establishing the verity of the pleaded [403]*403self-defense. In Commonwealth v. Yancer, 125 Pa. Superior Ct. 352, the court said (p. 356) :

“Our courts have uniformly held that defenses of insanity, self-defense and alibi are affirmative defenses and the burden of proving such defense, by a fair preponderance of the evidence, is placed upon the defendant. . . . We recognize that in alibi cases it is the duty of the court to fully advise the jury as to the difference between the burden of proof resting upon the Commonwealth to establish guilt and that resting on the defendant with respect to the alibi set up; but we find no authority in this state requiring such instructions in a plea of self-defense, although we see much ground for distinction in not requiring such instructions with respect to such plea. Unlike insanity, self-defense, excusable homicide, etc., an alibi defense does not admit the act charged and set up something by way of palliation or excuse; it denies the commission of the offense by the defendant, by asserting that he was somewhere else at the time”.

The quoted language recognizes the distinction between the pleas of alibi and self-defense, in that the plea of alibi does not, in and by itself, concede the perpetration of the act, but, if it was committed, assumes to establish the impossibility of the defendant’s having committed it by affirmatively proving his absence- at the alleged time and place of the offense. The plea of self-defense on the other hand necessarily and logically asserts and admits in and by itself that the act was committed, and seeks to excuse it by affirmatively proving circumstances which justify defendant’s violence. It will be observed, however, that the Superior Court stopped short of holding that it was unnecessary to charge upon reasonable doubt, saying at page 357:

“The court charged the jury that the burden was on the Commonwealth to the end of the case to prove defendant’s guilt beyond a reasonable doubt, yet the court would have been fully warranted in saying to the jury [404]*404that if it doubted, that is, unless it was satisfied by the preponderance of the evidence that the blows were struck in self-defense, the plea of self-defense had not been made out”.

. In a civil case where the interests of private litigants are involved, and the interest of the public is not involved, except remotely or secondarily, an admission by either party, or a theory of the case adopted and practiced at its trial by a party thereto, or a stipulation of both parties entered into, has a certain force in limiting the right of such party to take an opposite position after the trial is over. In a criminal case the interest of the Commonwealth is directly and primarily concerned that the transgressor shall not be acquitted, but that no innocent person shall be convicted. Neither defendant’s testimony nor the testimony of the Commonwealth’s witnesses, to whatsoever extent they agree in painting a picture of guilt, is conclusive of guilt if discredited by the jury. After the testimony is in, it does not in such case have the force and effect of a case stated in a civil suit. A jury may conceivably disbelieve the whole of the testimony. They may disbelieve that a quarrel ever occurred, or that a blow was struck by anyone. They may disbelieve defendant’s admission that he struck at all, or may reject his confession if such be formally offered. They may disbelieve the Commonwealth’s entire testimony to the altercation having occurred. It is true that their doubt as to a defendant’s guilt must be an honest doubt, and it must be engendered by some portion of the evidence offered. It is even true that where the plea is self-defense it must be something more than a doubt engendered by the failure of defendant to satisfy them that he was justified in striking the blow.

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Related

Commonwealth v. Troup
153 A. 337 (Supreme Court of Pennsylvania, 1930)
Commonwealth v. Yancer
189 A. 684 (Superior Court of Pennsylvania, 1936)
Commonwealth v. Di Silvestro
31 Pa. Super. 537 (Superior Court of Pennsylvania, 1906)

Cite This Page — Counsel Stack

Bluebook (online)
35 Pa. D. & C. 400, 1938 Pa. Dist. & Cnty. Dec. LEXIS 71, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-spohn-paqtrsessberks-1938.