G.R. No. 249616 - Mecaydor vs. Saekyung Realty Corp.

Charge and procedural history
On November 25, 2011, petitioner Reynaldo V. Valencia, a passenger jeepney driver in Legazpi City, was charged under Article 365 of the Revised Penal Code with reckless imprudence resulting in homicide for allegedly hitting pedestrian Celedonio Jaquilmo and failing to render assistance.
Valencia was arrested, posted bail, pleaded not guilty before the Regional Trial Court (RTC), was convicted, and the Court of Appeals (CA) affirmed with modifications. He filed a petition for review on certiorari with the Supreme Court.

Prosecution evidence
Passengers Reymer AAonuevo and Richard Nicerio testified that at around 4:30 a.m. on Sagumayon Bridge, they heard a loud thud and felt the jeepney shake; upon looking, they saw a man lying face down; they informed Valencia, who backed up, drove off without aiding the victim, and told them he would report to police; they noted the vehicle’s plate number.
Aurelio Macinas, Jr. testified that he heard the thud and a shout inside the jeepney, saw it backtrack away from the victim, and positively identified the driver.
SPO1 Gary Amaranto, PO1 Jaime Puto, and SPO3 Ramon Reolo found Celedonio Jaquilmo near the pavement with head injuries and bloodstains; he was taken to the hospital where he died of severe traumatic head injury.
Moises Jaquilmo, the victim’s son, testified that Valencia offered to give the jeepney’s insurance proceeds to the family to prevent litigation; Police Inspector Anthony Mark Ferwelo corroborated an offer to him on condition no criminal case would be filed.

Defense evidence
Valencia admitted driving through Sagumayon Bridge but denied hitting Jaquilmo, claiming the thud came from a manhole cover; he saw bystanders around the body and, with passengers aboard, did not stop.
Lorenzo Mirandilla, seated beside Valencia, testified that Jaquilmo was already lying on the road when the jeepney passed.
PO2 Jonell Abinion testified that Valencia reported a vehicular accident to him but refused to accompany him to the station due to having passengers.

Lower court rulings
RTC Branch 6, Legazpi City convicted Valencia of reckless imprudence resulting in homicide with the qualifying circumstance of failure to render assistance; sentenced him to an indeterminate term of 4 years 2 months 1 day to 6 years 1 month 11 days prision correccional, plus civil indemnities and damages.
CA Eleventh Division (CA-G.R. CR No. 37847) denied Valencia’s appeal; affirmed conviction with modifications: imposed 2 years 4 months to 6 years prision correccional, increased loss of earning capacity award, set moral and exemplary damages at ₱50,000 each, and ordered 6% interest on monetary awards.

Whether the CA erred in upholding Valencia’s conviction for reckless imprudence resulting in homicide despite alleged insufficiency of evidence to prove direct causal connection and inexcusable lack of precaution.