G.R. No. L-17584 - People vs. Santiago

Appellant Gregorio Santiago was driving an automobile at 30 miles per hour on a 6-meter-wide public highway.
He attempted to pass between a stationary wagon and a heap of stones where two young boys were standing; he failed to slow down or exercise due care, and his automobile struck and instantly killed 7-year-old Porfirio Parondo.

Santiago was charged with homicide by reckless negligence under Act No. 2886, convicted by the trial court, and sentenced to one year and one day of prision correccional plus costs.
On appeal to the Supreme Court, he assigned four errors: (a) Act No. 2886 is unconstitutional; (b) prosecution under that Act deprived him of due process; (c) the lower court lacked jurisdiction over his person and the subject matter; and (d) the trial court erred in finding him guilty and imposing sentence.

Whether Act No. 2886, which amends Section 2 of General Orders No. 58 by changing the prosecuting party’s name to “The People of the Philippine Islands,” is unconstitutional.
Whether prosecution under the allegedly unconstitutional Act No. 2886 violates due process and requires dismissal of the complaint.
Whether the trial court, acting under Act No. 2886, lacked jurisdiction over the person of the appellant and the subject matter of the offense.
Whether the trial court erred in finding the appellant guilty of homicide by reckless negligence and in imposing the sentence.