Title
Nueva Espana vs. People
Case
G.R. No. 163351
Decision Date
Jun 21, 2005
The Supreme Court upheld the conviction of the petitioner for reckless imprudence resulting in double homicide. The Court found that the factual findings of the trial court, affirmed by the Court of Appeals, were sufficient to establish liability. However, the Court modified the award of damages, reducing the amounts to ensure they were reasonable and proportionate to the offense committed. The Court also affirmed the subsidiary liability of the petitioner's employer. Lastly, the Court adjusted the penalty, considering the aggravating circumstance of the petitioner's failure to assist the victims after the collision. This decision ensures justice for the victims while maintaining the principles of proportionality and fairness in damages and penalties.

Case Digest (G.R. No. 228232)
Expanded Legal Reasoning Model

Facts:

  • Incident Details:
    • On May 15, 1998, at around 11:15 a.m., petitioner Antonio V. Nueva España was driving a passenger bus owned by Vallacar Transit, Inc. on the national highway of Calag-Calag, Ayungon, Negros Oriental.
    • While negotiating a curve, the bus collided with a northbound Honda motorcycle, resulting in the deaths of Reynard So (the motorcycle driver) and Nilo Castro (the passenger).
  • Prosecution's Case:
    • Eyewitness Julito Dayuday testified that the bus swerved from its lane and struck the motorcycle, dragging it about 24 meters. He also stated that the petitioner failed to assist the victims and instead walked away from the scene.
    • Florencio Banico, a passenger on the bus, corroborated Dayuday's testimony, adding that the victims were left unattended after the collision.
    • The fathers of So and Castro testified about their sons' earnings and the expenses incurred for their wakes and funerals.
  • Defense's Case:
    • SPO2 Dolger Germundo and SPO3 Hilbert Arinaza testified that the bus was in its proper lane and that the motorcycle rammed into the bus.
    • Roche Taburasa, the driver of a Suzuki motorcycle, claimed that So's motorcycle overshot its lane while attempting to overtake him, leading to the collision.
    • Petitioner denied the charges, claiming that he assisted the victims and reported the incident to the police.
  • Trial Court Decision:
    • The trial court convicted petitioner of reckless imprudence resulting in double homicide and imposed an indeterminate penalty of 6 months of arresto mayor to 6 years and 1 day of prision correcional. The court also awarded damages to the heirs of the victims.
  • Court of Appeals Decision:
    • The appellate court modified the penalty to 6 years of prision correcional as minimum to 8 years of prision mayor as maximum. It also adjusted the computation of lost earning capacity and affirmed the subsidiary liability of petitioner's employer.

Issues:

  • Whether the Court of Appeals erred in affirming petitioner's conviction despite alleged inconsistencies between the prosecution's evidence and the physical evidence.
  • Whether the award of damages totaling over P18 million was excessive and contrary to law and jurisprudence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.