Case Summary (G.R. No. L-4067)
Applicable Law
The case involves the interpretation and application of procedural rules under Rule 42 of the Rules of Court, particularly concerning the requirement for certifications of non-forum shopping and the presentation of material portions of the record during appeals.
Background of the Case
The case originated from an Information filed against Curammeng, charging him with Reckless Imprudence Resulting in Homicide, pursuant to Article 365 of the Revised Penal Code. It was alleged that Curammeng, while driving an RCJ bus, negligently collided with Francisco Franco, the driver of a stalled Maria De Leon bus that had suffered a tire blowout, leading to Franco's death.
MTC Findings
The MTC convicted Curammeng on November 26, 2013, citing his inexcusable lack of precaution while driving near the stalled bus. The court emphasized that Curammeng had failed to adequately decelerate and was running at approximately 60 kilometers per hour when the accident occurred. The MTC sentenced him to imprisonment ranging from four months and one day to four years and two months, imposed civil indemnity and actual damages to Franco's heirs.
RTC Affirmation
Curammeng's conviction was upheld by the RTC in a ruling dated June 3, 2014, which reiterated his duty as a professional driver to ensure the safety of himself, his passengers, and other road users. The RTC found that the lighting conditions and obstructed road visibility compounded his negligence leading to Franco’s death.
Appeals Dismissed by the CA
Curammeng's subsequent appeal to the CA was dismissed outright in a resolution on October 20, 2014, due to his failure to comply with procedural requirements, notably not attaching a certification of non-forum shopping and certain material records. His attempts to rectify this oversight were unsuccessful, as the CA denied reinstatement of his petition based on perceived lack of compelling reasons.
Supreme Court Review
The Supreme Court found the petition meritorious, holding that procedural compliance is essential but recognizing that it should not result in a miscarriage of justice. The court ruled that dismissing Cu
...continue readingCase Syllabus (G.R. No. L-4067)
Case Background
- The case revolves around Marlon Curammeng y Pablo (Curammeng), who is the petitioner in a petition for review on certiorari against the People of the Philippines, the respondent.
- The petition contests the Resolutions dated October 20, 2014, and June 30, 2015, issued by the Court of Appeals (CA), which dismissed Curammeng's petition for review due to his failure to attach a certification of non-forum shopping and other required documents.
Facts of the Case
- An Information was filed against Curammeng in the Municipal Trial Court of Bauang, La Union, accusing him of Reckless Imprudence Resulting in Homicide under Article 365 of the Revised Penal Code.
- The incident occurred on the night of September 25, 2006, when a Maria De Leon bus, driven by Francisco Franco y Andres, suffered a tire blowout and caught fire, leading to its parking on the national highway.
- On the following day, Curammeng, driving an RCJ bus bound for Manila, collided with Franco, who was near the stalled bus, resulting in Franco's death.
- Curammeng claimed he was driving under the speed limit (less than 60 kph) and attempted to decelerate upon seeing the stalled bus. He alleged that a closed van appearing from the opposite direction forced him to steer towards the shoulder of the road, leading to the collision.