G.R. No. 116013 - Soco vs. Court of Appeals

On January 4, 1972 at about 9:15 AM, Rodolfo Rayandayan was driving a Holden Kingswood car (plate No. 52-19V) owned by Sta. Ines Mining Corp., northbound on Ayala Avenue, Makati, Rizal.
At the intersection with Makati Avenue, Rayandayan stopped for the left-turn signal. While stationary, his car was struck from behind by a Blue Car Taxi (plate No. 55-71R) driven by Inocencio Tugade. The collision, attributed to Tugade’s defective brakes, caused P778.10 in damage.

Tugade was charged with Reckless Imprudence Resulting in Damage to Property.
He admitted the collision was due to brake malfunction but claimed the defect was not traceable to him.
The court found him guilty, imposed a P1,000 fine (with subsidiary imprisonment in case of insolvency), ordered indemnification of P778.10 for actual damages, and awarded costs.

Tugade appealed, reiterating that even due diligence could not have prevented the mechanical defect.
The CA, in a decision penned by Justice Agrava on December 15, 1977, affirmed the trial court in toto, holding that brake failure is not a fortuitous event excusing criminal liability.

Whether the malfunctioning of brakes constitutes a fortuitous event (caso fortuito) absolving the driver of criminal liability for reckless imprudence under the Revised Penal Code.
Whether the Court of Appeals erred in applying this Court’s decision in La Mallorca and Pampanga Bus Co. v. De Jesus—alleged by petitioner to be obiter dictum—and in failing to follow earlier Court of Appeals rulings.
Whether the fine imposed may be reduced for excessive penalty, as suggested by petitioner.