Case Digest (G.R. No. 125066)
Facts:
Isabelita Reodica v. Court of Appeals and People of the Philippines, G.R. No. 125066, July 08, 1998, First Division, Davide, Jr., J., writing for the Court. On 17 October 1987 petitioner Isabelita Reodica was driving a van in Parañaque and collided with the car of Norberto Bonsol, who sustained slight physical injuries and P8,542.00 worth of damage to his vehicle. On 20 October 1987 Bonsol filed an Affidavit of Complaint with the Fiscal’s Office. An information was filed on 13 January 1988 in the Regional Trial Court (RTC) of Makati as Criminal Case No. 33919 charging Reodica with Reckless Imprudence Resulting in Damage to Property with Slight Physical Injury.Upon arraignment petitioner pleaded not guilty; trial followed. On 31 January 1991 the RTC, Branch 145, convicted petitioner of the quasi-offense and sentenced her to six months of arresto mayor and ordered payment of P13,542 (representing P8,542 for car repairs and P5,000 for medical expenses). Petitioner appealed to the Court of Appeals (CA), docketed CA-G.R. CR No. 14660; the CA denied her motion to withdraw the appeal for probation purposes and, after briefing, affirmed the RTC decision on 31 January 1996. Petitioner filed a motion for reconsideration raising, inter alia, that the courts below misapplied the penalty (citing an erroneous citation of People v. Aguilar), that the two resulting quasi-offenses should have been charged separately rather than complexed, and that prescription and lack of jurisdiction barred prosecution; the CA denied reconsideration by Resolution of 24 May 1996.
Petitioner then filed a petition for review on certiorari under Rule 45 to the Supreme Court. The Office of the Solicitor General (OSG) filed a Comment joining petitioner on the penalty issue but defending the complexing and arguing that ...(Subscriber-Only)
Issues:
- May petitioner, for the first time on appeal, challenge the duplicity of the information for charging two offenses in one information?
- Did the Regional Trial Court have jurisdiction over Criminal Case No. 33919?
- Were the quasi-offenses charged already prescribed at the time the information was filed?
- Was the penalty imposed on petitioner correct?
- Are the quasi-offenses of reckless imprudence resulting in damage to property (P8,542.00) and reckless imprudence resulting in slight physical injuries light felonies?
- Does Articl...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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