Facts:

Teofilo Abueva y Cagasan is the petitioner in this case, while the People of the Philippines act as the respondent. The incident occurred on August 7, 1992, at the Ecoland Bus Terminal in Matina, Davao City. Abueva, an employee of Bachelor Express, Inc., was driving a Fuso bus registered under Vallacar Transit, Inc. On that day, as passengers boarded, including Lourdes Mangruban, Abueva allegedly started the bus and drove off without ensuring that all passengers were seated securely. Lourdes was standing on the first step of the bus when it suddenly moved, causing her to fall onto the cement pavement, resulting in severe injuries. Despite the incident, Abueva did not render any assistance to the injured passenger at that moment.

The Regional Trial Court of Davao City charged Abueva with reckless imprudence resulting in homicide. During trial, different testimonies emerged. The prosecution presented Ireneo Mangruban, Lourdes’s brother, who confirmed that Lourdes was about to boar

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Facts:

Incident and Charging

• On or about August 7, 1992, in Davao City, petitioner Teofilo Abueva y Cagasan, an employee of Bachelor Express, Inc. and driver of a FUSO BUS, was charged with reckless imprudence resulting in homicide.
• The charge stemmed from the allegation that while driving the bus from the terminal, petitioner, without taking due precaution, set the vehicle in motion before ensuring that all passengers were properly seated or secure.
• The resulting incident caused the passenger, Lourdes Mangruban, to fall from the bus and sustain severe head injuries that eventually led to her death.

Testimonies and Evidentiary Accounts

• Prosecution’s version:
• Ireneo Mangruban, the victim’s brother, testified that at around 6:00 A.M., while waiting at the Ecoland Bus Terminal, Lourdes was on the first stepboard of the bus when its sudden movement caused her to fall.
• Other witnesses, including dispatcher Raul Quiblat and laborers at the terminal, corroborated that the victim did not appear to be in the process of voluntarily alighting and noted that her injuries were consistent with a fall.
• Defense’s version:
• Melquiades Rojas, the bus conductor, testified that Lourdes signaled her intent to get off the bus by knocking on the ceiling and that she jumped out despite his warning to wait until the bus stopped.
• Additional accounts by other defense-affiliated witnesses provided a conflicting narrative which suggested that the victim’s own actions contributed to the mishap.

Trial Court Proceedings and Findings

• The Regional Trial Court of Davao City found petitioner guilty of reckless imprudence resulting in homicide.
• The court determined that petitioner’s failure to verify the safety of his passengers before moving the vehicle amounted to an inexcusable lack of precaution.
• Petitioner was sentenced to suffer a term of prision correccional alongside an order to pay civil liabilities covering medical expenses, funeral expenses, and indemnity.
• Subsequent motions:
• The prosecution’s motion for reconsideration resulted in an increased award for actual expenses.
• On appeal, the Court of Appeals affirmed the conviction while modifying the penalty by increasing it based on a qualifying circumstance.

Appellate Holdings and Conflicting Element on Assistance

• Qualification for an increased penalty hinged on whether petitioner failed to render immediate assistance to the injured party.
• Ireneo Mangruban testified that petitioner did not disembark to help after the victim’s fall.
• However, other evidence and testimonies indicated that petitioner did alight and observed that help was being rendered by terminal personnel and the bus dispatcher.
• The conflicting versions on whether the victim jumped or fell became central to the issue of the petitioner’s culpability.

Issues Raised on Review

• Petitioner contended that the lower courts misapprehended the facts, particularly emphasizing the credibility of the witness accounts more favorable to his version—that the victim jumped.
• Petitioner further challenged the imposition of the qualifying circumstance (failure to render on-the-spot assistance) as a basis for aggravating his sentence, asserting that he had rendered sufficient observation and assistance under the circumstances.

Issue:

Whether the prosecution proved beyond reasonable doubt that the victim, Lourdes Mangruban, fell off the bus as a result of petitioner’s reckless imprudence.

• Did the evidence support that petitioner’s negligent act, specifically starting the bus without verifying the safety of his passengers, directly caused the fatal incident?
• Is the credibility of the prosecution’s witnesses, particularly Ireneo Mangruban, sufficient to discount the conflicting account provided by the defense regarding the victim’s actions?

Whether the requirement of rendering immediate assistance, as a qualifying circumstance under the last paragraph of Article 365 of the Revised Penal Code, was adequately satisfied.

• Was there clear and convincing evidence that petitioner failed to give help at the moment of crisis, within the means available to him?
• How did the corroborative testimonies regarding the assistance rendered by others at the scene affect the determination of this alleged qualifying circumstance?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)