Case Digest (G.R. No. L-17584)
Facts:
The People of the Philippine Islands v. Gregorio Santiago, G.R. No. 17584, March 8, 1922, the Supreme Court En Banc, Romualdez, J., writing for the Court.The respondent in the criminal information was Gregorio Santiago (defendant and appellant); the prosecution was brought in the name of The People of the Philippine Islands (plaintiff and appellee). Santiago, while driving an automobile, struck and caused the death of Porfirio Parondo, a seven‑year‑old boy. He was charged with homicide by reckless negligence, tried by the trial court, convicted, and sentenced to one year and one day of prision correccional and to pay the costs of the trial.
Dissatisfied, Santiago appealed to the Supreme Court, assigning four errors: (1) that the trial court ought to have taken judicial notice that the prosecution proceeded under Act No. 2886 and that the Act is unconstitutional and thus divested the court of jurisdiction; (2) that the complaint should have been dismissed because prosecution under Act No. 2886 deprived him of due process; (3) that the court below lacked jurisdiction over his person and over the subject matter; and (4) that the conviction and sentence were erroneous. The trial judge’s factual findings — that Santiago was driving at about thirty miles per hour on a six‑meter road, failed to slow when negotiating a narrow space between a standing wagon and a heap of stones where two boys were present, and thereby ran over and killed the child — were reviewed on appeal and found by the Court to be well supported by the record.
On appeal the principal contested legal question became whether Act No. 2886, which amended section 2 of General Orders No. 58 to make prosecutions in the name of the “People of the Philippine Islands” rather than the “United States,” was constitutional and whether its use in the information affected jurisdiction or due process. The trial court’s convict...(Pro-only)
Issues:
- Was Act No. 2886, which amends section 2 of General Orders No. 58 to make prosecutions in the name of the People of the Philippine Islands, constitutional and within the Philippine Legislature’s power to enact?
- Did prosecution under Act No. 2886 violate the appellant’s right to due process so as to require dismissal of the complaint?
- Did the trial court lack jurisdiction over the person of the accused or the subject‑matter because of the change in the name of the plaintiff in the information?
- Was the conviction for homicide by reckless negligence and the sentence of one year and one da...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)