G.R. No. 172716 - Ivler y Aguilar vs. Modesto-San Pedro

In August 2004, petitioner Jason Ivler y Aguilar (“petitioner”) was involved in a vehicular collision with the vehicle of Evangeline L. Ponce. The accident resulted in:

Slight physical injuries to Ponce (Criminal Case No. 82367).
Death of Ponce’s husband, Nestor C. Ponce, and damage to the Ponces’ vehicle (Criminal Case No. 82366).

On 7 September 2004, petitioner pleaded guilty to Reckless Imprudence Resulting in Slight Physical Injuries (No. 82367) and received public censure.
Petitioner moved to quash the Information in No. 82366 on double jeopardy grounds; MeTC, in a 4 October 2004 Resolution, denied the motion for lack of identity of offenses.
Petitioner filed S.C.A. No. 2803 for certiorari with the RTC of Pasig City (Branch 157) and simultaneously moved MeTC to suspend proceedings in No. 82366. MeTC ignored the suspension motion, proceeded with arraignment on 17 May 2005, declared bail forfeited, and ordered petitioner’s arrest.
On 24 May 2005, MeTC denied the suspension motion; petitioner’s reconsideration remained unresolved.

Respondent Ponce moved to dismiss S.C.A. No. 2803 for petitioner’s alleged loss of standing due to absconding.
On 2 February 2006, RTC (Branch 157) granted the motion, dismissed S.C.A. No. 2803 without reaching its merits, and denied reconsideration on 2 May 2006.
Petitioner elevated the matter to the Supreme Court via a Rule 45 petition.

Whether petitioner’s non-appearance at the arraignment in Criminal Case No. 82366 divested him of standing to maintain S.C.A. No. 2803.
If standing was not lost, whether the Double Jeopardy Clause bars further proceedings in Criminal Case No. 82366 given petitioner’s prior conviction in No. 82367.