Case Digest (G.R. No. 240337)
Facts:
Francis O. Morales v. People of the Philippines, G.R. No. 240337, January 04, 2022, the Supreme Court En Banc, Carandang, J., writing for the Court.On May 14–15, 2013, an information charged Francis O. Morales (petitioner) with Reckless Imprudence Resulting in Damage to Property and Multiple Physical Injuries for an early‑morning collision in Angeles City between his Mitsubishi Delica van and an Isuzu jeepney owned by Noel G. Garcia and driven by Rico Mendoza, injuring Mendoza and several passengers and allegedly damaging the jeepney by P350,000. Petitioner pleaded not guilty and testified that the jeepney struck his vehicle; the prosecution presented three eyewitnesses (Rico, Leilani Mendoza, and Myrna Cunanan) who testified that petitioner overtook recklessly, encroached the jeepney’s lane and struck it.
The Municipal Trial Court in Cities (MTCC), Angeles City (Branch III), convicted petitioner on June 30, 2015, sentencing him to an indeterminate term of one month and twenty‑one days to two months and awarding hospitalization expenses, lost income, moral damages to some private complainants, and P350,000 for the jeepney’s repair. The MTCC denied petitioner’s motion for reconsideration (Order, August 25, 2015). Petitioner appealed to the Regional Trial Court (RTC), Angeles City, which, in a December 1, 2016 Decision, affirmed the MTCC’s findings that petitioner’s overtaking and encroachment were the proximate cause of the collision and damages.
Petitioner elevated the case to the Court of Appeals (CA). In a March 15, 2018 Decision (CA‑G.R. CR No. 39341) the CA affirmed conviction but modified penalties and awards: it imposed a straight penalty of two months and one day of arresto mayor; it deleted the lost‑income awards for some victims and substituted temperate damages (P8,000 to spouses Rico and Leilani Mendoza; P2,000 to Myrna Cunanan); and it reduced the jeepney award to temperate damages of P150,000 to Noel G. Garcia. The CA denied reconsideration (Resolution, June 22, 2018).
Petitioner filed a petition for review on certiorari before the Supreme Court (Rule 45). The Office of the Solicitor General (OSG) filed a comment defending the courts a quo. This Court, by Resolution dated September 21, 2020, denied the petition for lack of reversible error. Petitioner then filed the present Motion for Reconsideration, re‑urging that the Traffic Accident Report (TAR) and evidence were unreliable,...(Subscriber-Only)
Issues:
- Should the Court uphold petitioner’s conviction for reckless imprudence resulting in multiple physical injuries and damage to proper...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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