G.R. No. 192914 - Senit vs. People

On the morning of September 2, 2000, private complainant Mohinder Toor, Sr. was driving his Toyota pick-up north along Aglayan from Valencia with his wife Rosalinda Toor, their three-year-old son Mohinder Toor, Jr., and househelper Mezelle Jane Silayan as passengers.
Toor, Sr. turned left toward the center of Aglayan when a Super 5 bus driven by petitioner Napoleon D. Senit, traveling south from Malaybalay toward Valencia, attempted to overtake a slow-moving ten-wheeler truck from the right.
The petitioner, driving at a high speed, swerved to the right shoulder and applied the brakes to avoid collision, but still crashed into the right side of the pick-up at a right angle.
All passengers in the pick-up were injured, requiring hospitalization first at Bethel Baptist Hospital (which lacked adequate medical facilities) and then transfer to Bukidnon Doctor’s Hospital in Valencia City.

Rosalinda Toor suffered an open fracture of the right humerus and displaced fracture of the right femur requiring two surgeries; she became paralyzed and unable to work.
Mohinder Toor, Sr. sustained a complete fracture of the right scapular bone.
Mohinder Toor, Jr. sustained abdominal injury and a laceration on the right eye area requiring suturing.
Mezelle Jane Silayan suffered swelling in the frontal area of the head.
The Toyota pick-up bore damages amounting to P106,155.00.
Private complainant Toor, Sr. incurred approximately P580,000.00 in medical expenses for Rosalinda and P3,000.00 for Mezelle Jane’s treatment.

On May 30, 2001, the City Prosecutor of Malaybalay City charged petitioner with reckless imprudence resulting in multiple serious physical injuries and property damage under Article 365 in relation to Article 263 of the Revised Penal Code (RPC).
Petitioner pleaded not guilty on June 21, 2001.
During trial, after initial presentation of evidence for the defense, petitioner resigned his employment, moved residence, and became unlocatable, thus unable to present testimony.
On April 26, 2006, the Regional Trial Court (RTC) of Malaybalay City convicted petitioner in absentia and sentenced him to imprisonment and ordered indemnification: P50,000 for moral damages, P480,000 for medical expenses, and P80,000 for vehicle repair.
Petitioner filed a motion for new trial, alleging lack of notice of trial dates and mistaken belief that the case had been dismissed. This was denied on October 26, 2006 by the RTC for being self-serving and because notices were duly served.
Petitioner appealed to the Court of Appeals (CA), which on November 20, 2009 affirmed the RTC decision with modification of penalty to three months and one day of arresto mayor (minimum and medium period).
Petitioner’s motion for reconsideration was denied by the CA on June 17, 2010.
The case was elevated to the Supreme Court via a petition for review on certiorari.

Whether or not the RTC and the CA erred in denying the petitioner’s motion for new trial or to re-open the case to allow presentation of evidence on his behalf.
Whether or not the RTC erred in convicting petitioner despite an alleged failure of the prosecution to prove guilt beyond reasonable doubt.