G.R. No. 210129 - Paman vs. People

On October 14, 2004, at about 1:20 p.m., Ursicio Arambala was riding his motorcycle along Roxas Street, Pagadian City, en route to the Southern Mindanao Colleges Main Campus.
At the intersection of Roxas and Broca Streets, a multicab driven by S/SGT. Cornelio Paman crossed Arambala’s path, colliding with his motorcycle.
The collision caused Arambala to be thrown from his motorcycle, with his head striking the pavement.
Emilda Salabit, an eyewitness standing beside the road, immediately assisted by hailing a tricycle and transporting Arambala to a hospital.
Medical examinations (including a CT Scan) revealed that Arambala suffered a cerebral hematoma.
Due to the injury, Arambala was confined at Mercy Community Hospital on October 15, 2004, and was later re-admitted on October 24, 2004 at the Zamboanga del Sur Provincial Hospital because of erratic blood pressure and slurring speech.

On February 21, 2005, an Information for reckless imprudence resulting in serious physical injuries (Criminal Case No. 14034) was filed against Paman at the Municipal Trial Court in Cities (MTCC) of Pagadian City.
Paman pleaded not guilty.
After due proceedings, on February 11, 2010, the MTCC rendered a judgment finding Paman guilty beyond reasonable doubt and sentenced him to an indeterminate penalty ranging from one (1) month and one (1) day to four (4) months of arresto mayor, to be served at the Pagadian City Jail, along with costs against him.

The Regional Trial Court (RTC) of San Miguel, Zamboanga del Sur, Branch 29, reversed the MTCC’s decision on July 12, 2011.
The RTC acquitted Paman, basing its decision on the finding that Arambala was partially or wholly at fault for the accident, as Arambala had seen the multicab in time and could have taken precautionary measures.

The City Prosecutor filed a motion for reconsideration before the RTC, which was denied on August 16, 2011.
The People of the Philippines, through the Office of the Solicitor General (OSG), filed a petition for certiorari with the Court of Appeals (CA) alleging that RTC Presiding Judge Edilberto G. Absin committed grave abuse of discretion.
On July 4, 2013, the CA rendered a decision setting aside the RTC’s acquittal and finding Paman guilty beyond reasonable doubt, sentencing him to suffer an indeterminate penalty ranging from one (1) month and one (1) day of arresto mayor (minimum) to two years and four (2) months of prision correccional (maximum).
Paman sought reconsideration of the CA Decision, but the CA denied his reconsideration on October 30, 2013.

Paman filed a petition for review on certiorari before the Supreme Court, arguing that Judge Absin did not abuse his discretion in granting his acquittal at the RTC.
Paman contended that a petition for certiorari was not the proper remedy against the RTC’s decision and maintained that the evidence was insufficient to convict him, alleging that the collision was caused solely by Arambala’s failure to accelerate.

Whether the petition for review on certiorari is the proper remedy to assail the RTC’s acquittal of Paman.
Whether the application of Rule 65 (certiorari) is justified despite the general rule of finality of an acquittal.

Whether the evidence sufficiently establishes that Paman’s act of driving on the wrong side of the road and attempting an unsafe overtaking maneuver was the proximate cause of the collision.
Whether the RTC erred in attributing fault solely to Arambala based on his alleged contributory negligence.
Whether the prosecution’s evidence proves beyond reasonable doubt that Paman violated traffic regulations and was negligent at the time of the incident.

Whether the imposition of an indeterminate sentence based on the Indeterminate Sentence Law is applicable in this case.
How the penalty should be calibrated in light of the Revised Penal Code provisions regarding reckless imprudence and serious physical injuries.