Case Digest (G.R. No. 131675)
Facts:
Reynaldo S. Mariano v. People of the Philippines, G.R. No. 178145, July 07, 2014, First Division, Bersamin, J., writing for the Court.The petitioner, Reynaldo S. Mariano, was charged by the Office of the Provincial Prosecutor of Bulacan with frustrated murder in relation to an incident on September 12, 1999 in Angat, Bulacan, involving Ferdinand de Leon. The information alleged that Mariano, while driving a motor vehicle, with evident premeditation, treachery and abuse of superior strength, hit and ran over de Leon, performing all acts of execution which should have produced the crime of murder but did not by reason of causes independent of his will.
The factual background, as summarized by the Court of Appeals (CA), was that at about 6:30 p.m. on September 12, 1999 de Leon was driving his jeep with family members after a baptismal party when a red Toyota pick-up driven by Mariano overtook and almost bumped his jeep. After a brief roadside altercation that subsided, de Leon later stopped and parked in front of his mother’s house; he was subsequently struck by a moving vehicle identified by witnesses as Mariano’s pick-up, thrown about four meters, and rendered unconscious. De Leon sustained multiple facial injuries, a fractured inferior part of the right orbital wall, and subdural hemorrhage secondary to severe head trauma, and incurred documented medical expenses.
At trial in the Regional Trial Court (RTC), Branch 81, Malolos, Bulacan, the RTC found Mariano guilty of frustrated homicide (a lesser offense) and sentenced him to an indeterminate term and awarded damages. On appeal the CA, in a decision promulgated June 29, 2006, modified the conviction to reckless imprudence resulting in serious physical injuries, sentenced Mariano to an indeterminate penalty (two months and one day of arresto mayor to one year, seven months and eleven days of prision correccional), and awarded actual damages of P58,402.75 and moral damages of P10,000.00.
Mariano appealed to the Su...(Subscriber-Only)
Issues:
- Was the petitioner’s guilt for any criminal offense proved beyond reasonable doubt?
- Whether the petitioner’s act constituted reckless imprudence resulting in serious physical injuries rather than a grave felony and whether voluntary surrender should be appreciated as a mitigating circumstance.
- Whether the penalty imposed by the Court of Appeals was the correct penalty for the offense proved.
- Whether the awards of actual and moral damages an...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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