G.R. No. L-25366 - People vs. Buan

The accused-appellant, Jose Buan, was charged in the Court of First Instance (CFI) of Bulacan with serious physical injuries and damage to property through reckless imprudence (Criminal Case No. 5243).
Prior to this, the accused had been charged and tried before the Justice of the Peace Court of Guiguinto, Bulacan for slight physical injuries through reckless imprudence arising from the same incident and was acquitted on December 16, 1963.
The accused moved to quash the charges in the CFI on the ground of double jeopardy, which motion was denied, prompting an appeal to the Supreme Court.

On July 23, 1962, Jose Buan was driving a passenger bus owned by La Mallorca Company along MacArthur Highway in Guiguinto, Bulacan.
Allegedly due to his negligence and recklessness, the bus collided with a passenger jeepney driven by Sergio Lumidao, causing the jeep to overturn ("turn turtle").
Damage resulting from the collision included:

Slight physical injuries to six passengers requiring medical treatment from 5 to 9 days.
Serious bodily injuries to three other passengers requiring medical attention for 30 to 45 days.
Damage to the jeep amounting to P1,395.00.

The Justice of the Peace Court charged the accused with slight physical injuries through reckless imprudence; he was acquitted.
The Provincial Fiscal filed charges for serious physical injuries and damage to property through reckless imprudence in the CFI based on the same act.
The counsel for the accused moved to quash the latter charges, asserting double jeopardy, but the CFI denied the motion.

Whether the prosecution for serious physical injuries and damage to property through reckless imprudence after an acquittal for slight physical injuries through reckless imprudence, both arising from the same incident, constitutes double jeopardy and is therefore barred.