Case Digest (G.R. No. L-2621)
Facts:
- Jesus Guanco was charged with violating Act No. 3992, the Motor Vehicle Law.
- The incident occurred on June 30, 1946, when Guanco drove a jeep on a public highway in Negros Occidental.
- He was carrying fourteen passengers and was driving at a prohibited speed of 50 to 60 miles per hour.
- The jeep overturned into a ditch, resulting in the deaths of four passengers.
- Guanco was under 18 years old and lacked a valid driver's license, violating Section 27 of the Motor Vehicle Law.
- He was initially convicted by the Justice of the Peace Court of Hinigaran, fined P50, and sentenced to subsidiary imprisonment if unable to pay.
- Guanco appealed to the Court of First Instance of Negros Occidental, which upheld the conviction.
- His motion for a new trial was denied, prompting an appeal to the Supreme Court.
- In a separate case, he was convicted of multiple homicide through reckless imprudence for the same incident and committed to the Training School for Boys until adulthood.
- Guanco claimed he faced double jeopardy due to the two convictions.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the lower court's judgment, ruling that Guanco had not been subjected to double jeopardy.
- The Court determined that the offen...(Unlock)
Ratio:
- The Court explained that the two offenses were separate under the law.
- The charge for violating the Motor Vehicle Law pertained to driving without a license, while the multiple homicide charge was linked to negligent driving causing fatalities. ...continue reading
Case Digest (G.R. No. L-2621)
Facts:
The case involves Jesus Guanco, the defendant and appellant, who was charged with violating Act No. 3992, known as the Motor Vehicle Law. The events took place on June 30, 1946, when Guanco drove a jeep on a public highway between the municipalities of Hinigaran and Pontevedra in Negros Occidental. At the time, he was carrying fourteen passengers and was driving at a prohibited speed of 50 to 60 miles per hour. The jeep subsequently turned turtle into a ditch, resulting in the deaths of four passengers. Notably, Guanco was less than 18 years old and did not possess a valid driver's license, which constituted a violation of Section 27 of the Motor Vehicle Law.
Initially, Guanco was convicted by the Justice of the Peace Court of Hinigaran and sentenced to pay a fine of P50, with subsidiary imprisonment in case of insolvency, along with the costs. He appealed this decision to the Court of First Instance of Negros Occidental, which upheld the conviction. Guanco then filed a motion for a new trial, which was denied, leading him to appeal to the Supreme Court. In a separate case, Guanco had also been convicted of multiple homicide ...