G.R. No. 248202 - People vs. Macalindong y Andallon

Saturnino Bayasen, the petitioner, was charged with homicide through reckless imprudence resulting from a vehicular accident.
The charge stemmed from an incident on or about August 15, 1963, in which the Rural Health Unit jeep, driven by Bayasen, allegedly ran off a precipice in Sagada, Mountain Province.
The petitioner was originally tried in the Court of First Instance of Mountain Province, Second Judicial District, in Criminal Case No. 1056, where he was convicted and sentenced to an indeterminate penalty and ordered to pay certain compensatory damages, attorney’s fees, burial expenses, and costs.

On the morning of August 15, 1963, Bayasen, then serving as Rural Health Physician in Sagada, drove his jeep to barrio Ambasing.
Two nurses, Elena Awichen and Dolores Balcita, passengers in the jeep, joined him at Ambasing to be taken further to barrio Suyo.
While en route, at barrio Langtiw, the jeep went over a precipice and came to rest against a pine tree located about eight feet below the road.
The accident resulted in Elena Awichen sustaining fatal injuries (including a skull fracture) after being thrown from the jeep.

At trial, the petitioner was convicted of homicide through reckless imprudence with the following impositions:

An indeterminate arresto mayor penalty ranging from a minimum of Four (4) Months and One (1) Day to a maximum of One (1) Year, Seven (7) Months and Ten (10) Days of prision correccional.
Payment of compensatory damages, attorney’s fees, and burial expenses.

On appeal, the Court of Appeals (CA) affirmed and modified the trial court’s decision:

The CA increased the indemnity from P3,000.00 to P6,000.00.
It set aside the award for attorney’s fees.
It raised the maximum prison term to One (1) Year, Seven (7) Months, and Seventeen (17) Days.

The petition for certiorari was subsequently filed by Bayasen to challenge the CA decision on several grounds.

The prosecution’s primary evidence was the testimony of Dolores Balcita, who recounted:

The vehicle was driven at a moderate speed before the accident.
She did not observe any incident (such as a bump or jolt) immediately before the vehicular mishap.
There was no evidence of any irregularity with the jeep, nor were there distracting conversations occurring among the passengers.

Additional corroboration came from Pablo Lizardo, then mayor of Sagada, who observed that the jeep was in second gear after the incident—supporting moderate speed.
The petitioner testified that:

Prior to the accident he had observed skidding of the rear wheels.
He took immediate corrective action by steering the jeep toward the side of the mountain.
The accidental maneuver was involuntary and resulted from an unforeseen loss of traction rather than deliberate or negligent driving.

The Court of Appeals erred in attributing negligence to him based on previous incidents and presumed recklessness.
The finding of “unreasonable speed” as the proximate cause of Awichen’s death was contrary to the evidence.
There was no direct, legally sufficient proof that his driving was negligent.

The petitioner’s motion for reconsideration was denied by a majority of CA justices, with only Justice Magno S. Gatmaitan dissenting in favor of a renewed review.

Whether the Court of Appeals erred in finding that the petitioner’s negligence, specifically driving at an “unreasonable speed,” was the proximate cause of Elena Awichen’s death.

Did the CA improperly establish a presumption of negligence by considering alleged previous incidents not directly related to the accident?

Whether the evidence produced by the prosecution, particularly the testimony of Dolores Balcita, sufficiently demonstrated that Bayasen was driving at an unreasonable speed at the time of the accident.

Could the moderate speed testified by the prosecution’s principal eyewitness be reconciled with the allegation of reckless driving?

Whether the petitioner’s own testimony regarding the unforeseen skidding of the rear wheels and his corrective maneuver should have led to an acquittal due to the absence of culpable negligence.

Did the CA commit a reversible error by not giving proper weight to the positive and consistent testimony of the petitioner?