G.R. No. 116600 - People vs. Manlusoc

On October 30, 1954, Benigno Lingad y Vito, while driving a pick-up (Plate No. T-518, Cavite-'54) on Arroceros Street in Manila, was involved in an accident.
The vehicle he operated collided with a car (Plate No. PI-2578, Manila) driven by Detective Mariano Joaquin.
As a result of the collision, Mayor Arsenio Lacson, a passenger of a third vehicle (Plate No. PI-2573), sustained physical injuries that required medical attention for a period exceeding one day but less than ten days, preventing him from engaging in his customary labor.

Lingad y Vito was charged with the crime of slight physical injuries committed through reckless imprudence.
In the Municipal Court of Manila, after trial, he was found guilty and sentenced to pay a fine of P50, with subsidiary imprisonment in case of insolvency, plus the costs of the proceedings.
On appeal to the Court of First Instance, the accused filed a motion to quash the information.

The trial court granted the motion and dismissed the case.
The dismissal was founded on the contention that the crime of slight physical injuries when committed through reckless imprudence is not punishable by law, citing a decision in People vs. Macario Ande y Marino and a portion of Article 365 of the Revised Penal Code.

The information alleged that Lingad y Vito drove the pick-up “in a careless, reckless, negligent and imprudent manner” and at a speed “greater than was reasonable and proper.”
The information did not clearly specify whether the negligence was of a reckless or simple nature.

This vagueness raised the possibility that the act could be proven as either reckless or simple negligence, depending on the nature of the evidence presented.
The government argued that the inherent ambiguity allowed for the possibility that the more serious form (reckless imprudence) might automatically include a charge for the lesser form (simple negligence).

The Court held that the information’s wording allowed for evidence to substantiate either charge—reckless or simple negligence.
The majority maintained that even if intended as reckless imprudence, evidence might eventually establish simple negligence, which remains punishable by law.

The dissent contended that the trial court erred by dismissing the case and that remanding the case for trial on its merits would subject the defendant to double jeopardy.
The dissent extensively argued that the defendant’s conviction in the inferior court, although quashed on appeal, should serve as a bar to subsequent prosecutions under the principle of double jeopardy as enshrined in both the Rules of Court and the Constitution.

Whether the information, by referring generally to “careless, reckless, negligent and imprudent” conduct, is sufficient to charge the defendant under the ambit of reckless imprudence.
Whether the vagueness in the specification of the kind of negligence (reckless versus simple) precludes the prosecution from proving the necessary elements for conviction.

Whether the punitive provisions of Article 365, which impose a fine and censure for a wrong done through simple negligence, extend to acts committed through reckless imprudence.
How the principle that “what is more or graver includes the less or lighter” applies in the context of the offense charged.

Whether the remanding of the case to the trial court for a new trial on the merits constitutes placing the defendant in double jeopardy.
How the principles of double jeopardy, as provided under Section 1-(20) of the Bill of Rights and Section 9 of Rule 113 of the Rules of Court, are reconciled with the Court’s decision to set aside the lower court’s dismissal.