It only has "databases", which are accessed record by record (as opposed to the Unix byte-stream model). I suppose you could use one of these to emulate files, but it wouldn't interact with anything, and so would not be useful.

To make a Palm language useful, you have to provide access to the databases (as records, not as bytes). And ideally, you'd have some GUI layer so that you could interact and respond to the many PalmOS events (like being put to sleep).