G.R. No. 125066 - Reodica vs. Court of Appeals

On the evening of October 17, 1987, petitioner Isabelita Reodica was driving a van along Doña Soledad Avenue, Better Living Subdivision, Parañaque, Metro Manila.
Due to alleged recklessness, her van collided with the car of complainant Norberto Bonsol.
The collision caused physical injuries to Bonsol and damage to his car amounting to ₱8,542.00.

Bonsol filed an Affidavit of Complaint against petitioner at the Fiscal’s Office on October 20, 1987, three days after the incident.
An information was filed on January 13, 1988, in the Regional Trial Court (RTC) of Makati, docketed as Criminal Case No. 33919, charging petitioner with reckless imprudence resulting in damage to property with slight physical injuries.
The information alleged that petitioner drove recklessly causing bodily injuries to Bonsol, who was incapacitated less than nine days and property damage amounting to ₱8,542.00.

Petitioner pleaded not guilty. Trial ensued.
On January 31, 1991, RTC Branch 145 convicted petitioner of reckless imprudence resulting in damage to property with slight physical injuries.
Petitioner was sentenced to six (6) months of arresto mayor (imprisonment) and ordered to pay ₱13,542.00 (₱8,542.00 for car repairs and ₱5,000.00 for medical expenses), plus costs.
The court justified the prison term, citing precedents that slight physical injuries through reckless imprudence merit maximum arresto mayor.

Petitioner appealed, filing motions for extension of time and a motion to withdraw appeal for probation, which the CA denied.
The CA, after reviewing petitioner's stated errors, affirmed the RTC’s decision on January 31, 1996.
Petitioner filed a motion for reconsideration and supplemental motion, raising new issues on penalty excess, jurisdiction, and prescription, which the CA denied on May 24, 1996.

The penalty imposed (six months arresto mayor) was excessive, based on a misquoted precedent (People v. Aguilar, not Aguiles), where penalty for slight physical injuries through reckless imprudence was arresto menor.
There were actually two separate light felonies (reckless imprudence with slight physical injuries and reckless imprudence with damage to property), improperly combined as a complex crime and punished with a single excessive penalty.
The offenses had prescribed, as slight physical injuries through reckless imprudence is a light felony with a two-month prescriptive period, and the information was filed almost three months after the incident.
The RTC lacked jurisdiction because both offenses constitute light felonies covered under summary procedure, proper jurisdiction being the Metropolitan or Municipal Trial Courts.

Agreed that penalty imposed was incorrect but argued maximum arresto menor was correct penalty for slight physical injuries.
Supported the complexing of the two offenses under the single act of recklessness as proper under Buerano v. Court of Appeals, to avoid splitting the crime.
Argued the RTC had jurisdiction because it could impose the higher penalty applicable to damage to property.
Contended prescription was tolled by the filing of the complaint with the fiscal’s office.

Appreciated OSG’s agreement on penalty but disagreed with the complexing argument, citing cases supporting separation of informations for damage to property and physical injuries.
Argued that RTC jurisdiction depended on proper classification and that prescription was not tolled by filing complaint with fiscal’s office as decided in Zaldivia v. Reyes.

Is the penalty of six months of arresto mayor properly imposed for reckless imprudence resulting in damage to property with slight physical injuries?
Are reckless imprudence resulting in damage to property in the amount of ₱8,542 and slight physical injuries classified as light felonies?
Does the rule on complex crimes under Article 48 of the Revised Penal Code apply to these quasi offenses?
Can the accused question for the first time on appeal the duplicity of the information charging multiple offenses in one?
Did the Regional Trial Court have jurisdiction over the offenses charged?
Have the charged quasi offenses already prescribed at the time of filing of the information?