Case Summary (G.R. No. L-20455)

Criminal Procedure and Damages to Property

• An award for damages to property is improper when the information only charges homicide and physical injuries.
• An accused cannot be convicted or sentenced for damages not included in the charges against them.

Applicability of Article 2207 of the Civil Code

• Article 2207 of the Civil Code pertains specifically to damages to property and does not apply to damages resulting from loss of life or injury to natural persons.
• The principle of "expressio unius est exclusio alterius" indicates that damages related to human life or injury are excluded from Article 2207's scope.

Contributory Negligence and Overloading

• The overloading of a vehicle involved in an accident does not constitute contributory negligence.
• The legal responsibility for damages remains with the party at fault, regardless of the circumstances surrounding the other vehicle.

Homicide Through Reckless Negligence

• In cases of homicide through reckless negligence, the absence of malice does not mitigate the liability of the accused.
• Reckless negligence is sufficient to establish criminal liability, irrespective of intent.

Liability of Necessary and Essential Industries

• Engaging in a necessary and essential industry does not justify a reduction in liability for damages caused to third parties.
• The law treats all industries equally concerning responsibility for damages, without special considerations for essential industries.

Appeal and Court Findings

• The appeal by Nazario Catuiza contests the award for damages to the jeep, the treatment of insurance payments, and the claims of contributory negligence.
• The Court of Appeals affirmed the lower court's ...continue reading