G.R. No. L-11302 - People vs. Aguilar y Perez

The case involves the defendant-appellees, Benjamin Aguilar y Perez and Jose Oliveros y Olat, who were charged in the Municipal Court of Manila on June 24, 1955.
They were accused of having committed multiple slight physical injuries through reckless imprudence during a vehicular collision.

On or about April 25, 1955, in Manila, the accused were operating a passenger jeepney (Plate No. TPU-2271) and a Liberty taxicab (Plate No. 3165), respectively.
It was alleged that both drivers, being in charge of their vehicles, drove in a careless, reckless, negligent, and imprudent manner along the corner of Requesens and Oroquieta streets.

As a consequence of their reckless driving, the two vehicles collided with each other.
The impact resulted in injuries sustained by five passengers of the jeepney:

The injuries required medical attention for a period exceeding one day but not more than nine days, temporarily incapacitating the victims from their customary labor.

The defendants filed motions to quash the information on the ground that reckless imprudence is punishable only if the act committed constitutes a grave or less grave felony.
Both the Municipal Court and the Court of First Instance of Manila sustained these motions, ultimately dismissing the case based on the interpretation that the facts alleged did not amount to an offense for which a penalty was provided under the relevant provisions of law.

The charges were anchored on Article 365 of the Revised Penal Code, which distinguishes between acts committed by reckless imprudence and those by simple negligence.
The statutory text specifically provides penalties for acts that, if intentional, would constitute either a grave felony or a less grave felony, but does not expressly include an act that would constitute a light felony if done intentionally.
The legislative gap in addressing slight physical injuries through reckless imprudence was later filled by Republic Act No. 1790 in 1957, prescribing the penalty of arresto menor in its maximum period for light felonies committed through reckless imprudence or negligence.

Whether the facts alleged in the information sufficiently describe an act committed through reckless imprudence or simple negligence, thereby invoking criminal liability.
Whether the manner in which the act was described (i.e., vague reference to “careless, reckless, negligent and imprudent manner”) allows for the prosecution under Article 365 given its distinctions between degrees of negligence.

Whether the omission in Article 365 regarding an act which, if performed intentionally, would constitute a light felony should preclude the prosecution of slight physical injuries committed through reckless imprudence.
Whether the rule of "inclusio unius est exclusio alterius" should limit the application of the article strictly to the offenses explicitly enumerated by the law, or if evidence of negligence may be used to elevate the charge.

Whether the evidence can sufficiently distinguish between reckless and simple negligence in order to establish the appropriate degree of criminal liability.
Whether the alleged negligent conduct, when examined through evidence at trial, might encompass elements of both recklessness and negligence, warranting criminal prosecution.