Case Digest (G.R. No. 107125) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The petition concerns Criminal Case No. 066 filed on June 1, 1983 before the Regional Trial Court of Santiago, Isabela, Branch 21, charging George Manantan with reckless imprudence resulting in homicide after a vehicular accident on September 25, 1982 along the Maharlika Highway at Barangay Malvar, Santiago, Isabela. Private respondents spouses Marcelino Nicolas and Maria Nicolas lost their son Ruben Nicolas, a passenger in the accused’s Toyota Starlet, when it allegedly sideswiped an oncoming jeepney, rolled over, and caused the youth’s death. The group had spent the day shrimping at a local farm, drinking beer, bowling, and visiting a night club before returning home under Manantan’s driving. Prosecution witnesses asserted that Manantan was intoxicated and drove negligently at 80–90 kph on the wrong lane, while defense witnesses maintained he drove slowly in his lane when the jeep suddenly swerved. On August 4, 1988 the trial court acquitted Manantan of criminal liability with Case Digest (G.R. No. 107125) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Information and Arraignment
- On June 1, 1983, the Provincial Fiscal of Isabela filed an information against George Manantan for reckless imprudence resulting in homicide, alleging that on September 25, 1982, he negligently drove a Toyota Starlet (Plate No. NGA-816) along the Daang Maharlika at Barangay Malvar, Santiago, Isabela, sideswiping a passenger jeepney (Plate No. 918-7F) and causing the death of passenger Ruben Nicolas.
- Upon arraignment, Manantan pleaded not guilty, and trial on the merits ensued.
- Pre-Accident Sequence
- Morning of September 25, 1982: Fiscal Wilfredo Ambrocio invited deceased Ruben Nicolas to catch shrimps at his farm. They borrowed Manantan’s Ford Fiera, picked up Manantan, and consumed one or more cases of beer at the Manantan Technical School and the farm.
- Afternoon and evening: After returning home, they ate a duck with another case of beer at Ambrocio’s house. Around 8:30 p.m., Manantan drove them to Vicap Bowling Lanes (no vacant alley), then to LBC Night Club where they drank and took lady partners, and finally to a nearby store for arroz caldo before heading home.
- Accident Circumstances
- Manantan drove the Toyota Starlet with Tabangin in front, Ambrocio and Nicolas in back. According to Manantan, speed was about 30–40 km/h on the right lane; according to the jeepney driver, 80–90 km/h on the wrong lane. They encountered a jeepney with bright lights; Manantan swerved right but collided head-on.
- The car rolled over twice, landed upside down; Ambrocio and Tabangin were injured (Ambrocio briefly unconscious), Ruben Nicolas died at Flores Clinic that night.
- Trial Court and Appellate Civil Proceedings
- RTC, Branch 21, Santiago, Isabela, issued a decision on June 30, 1988 (promulgated August 4, 1988) acquitting Manantan of reckless imprudence resulting in homicide, without ruling on civil liability.
- Spouses Marcelino and Maria Nicolas appealed the civil aspect (CA-G.R. CV No. 19240). On January 31, 1992, the Court of Appeals modified the judgment, held Manantan civilly liable, and awarded P104,400.00 (loss of support), P50,000.00 (death indemnity), and P20,000.00 (moral damages)—total P174,400.00. A motion for reconsideration was denied on August 24, 1992. Petitioner then elevated the case to the Supreme Court.
Issues:
- Whether the trial court’s acquittal of petitioner foreclosed further inquiry into his negligence or reckless imprudence, constituting double jeopardy.
- Whether the appellate court erred in holding that petitioner’s acquittal did not extinguish his civil liability.
- Whether the Court of Appeals lacked jurisdiction to award damages and indemnity due to non-payment of filing fees, invoking the Manchester doctrine.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)