Case Summary (G.R. No. L-2746)
Facts of the Case
On the morning of June 25, 1997, Dionesio Inguito, Sr. was driving his motorcycle with his two minor children, Dionesio, Jr. and Cherry, to school along a curving road in Barangay Kiara, Don Carlos, Bukidnon. While ascending on their proper right lane, Rogelio was descending swiftly in a Toyota Land Cruiser on the opposite lane but invaded the motorcycle's lane. Despite Dionesio, Sr.'s horn signals to return to his lane, Rogelio did not comply. An attempt to avoid collision resulted in a head-on impact, throwing the victims off the motorcycle. Dionesio, Sr. was pinned under the vehicle and later died; his children suffered serious leg injuries.
Immediate Incident Response
Bystanders Rolf, Cherry, and Jenny Ann Aquino rendered aid, placing the victims on the roadside. Rolf sought assistance from Kagawad Nerio Dadivas, who transported the victims to the hospital. Rogelio remained at the scene and reportedly attempted to assist by retrieving Dionesio, Sr. and the motorcycle from beneath the Land Cruiser with the help of others, but claimed his vehicle had defective brakes, necessitating a change of transport to the hospital.
Charges and Trial Proceedings
Rogelio was charged with Reckless Imprudence Resulting to Homicide with Double Serious Physical Injuries and Damage to Property, with an aggravating circumstance of failure to immediately extend aid, as provided under Article 365 in relation to Article 263 of the RPC. Rogelio pleaded not guilty, asserting that he was in his proper lane and that the motorcycle, ridden erratically by Dionesio, Sr., collided into his vehicle.
RTC Decision
The Regional Trial Court (RTC) convicted Rogelio beyond reasonable doubt. It found that Rogelio was driving fast on the wrong side of the road, which directly caused the collision and resulting fatalities and injuries. The RTC initially imposed the penalty of prision correccional maximum as minimum to prision mayor medium as maximum and ordered various civil liabilities. It also found that Rogelio failed to give prompt assistance, justifying the penalty next higher in degree.
Reconsideration and Modification by RTC
Upon motion for reconsideration, the RTC partially granted relief by reducing the penalty after revisiting the evidence on aid rendered. The court acknowledged plausible assistance by Rogelio, considering the use of the jack handle to retrieve the pinned victim, and thus mitigated the penalty accordingly.
Court of Appeals (CA) Ruling
The CA reinstated the original RTC penalty and decision without discussing the mitigating factor regarding the aid rendered to the victims. It upheld Rogelio’s conviction and the imposition of the higher penalty.
Issue on Review by the Supreme Court
The principal issue was whether the CA correctly affirmed the conviction and penalty based on the RTC’s decision.
Legal Analysis on Reckless Imprudence
Reckless imprudence under Article 365 of the RPC requires that a person voluntarily commits or omits an act with inexcusable lack of precaution resulting in material damage, taking into account relevant circumstances. To establish liability for negligent driving, a direct causal link between imprudent driving and harm must be proven, along with evidence of willful or wanton disregard for the safety of others, going beyond mere negligence.
Supreme Court Findings on Factual and Legal Matters
The Supreme Court affirmed that Rogelio drove fast on the wrong side of a curve, which is inherently dangerous and indicative of imprudence. Motorists have a duty of ordinary care to regulate speed to maintain control, especially when negotiating curves. Failure to do so resulting in collision establishes criminal recklessness. The Court emphasized that excessive speed near curves is a recognized ground for negligence.
Consideration of Aid to Victims and Penalty Imposition
While the CA endorsed the RTC’s original imposition of penalty next higher in degree due to failure to render aid, the Supreme Court noted conflicting testimonies. It highlighted the victim Cherry’s admission that victims were initially loaded onto Rogelio’s vehicle before transferring to another vehicle due to brake failure. This supported Rogelio’s claim of attempting to assist. Consequently, the Court ruled that the perceived failure to lend aid should not be considered in the penalty stage.
Penalty Modification and Application of Indeterminate Sentence Law
R
...continue readingCase Syllabus (G.R. No. L-2746)
Facts of the Case
- On June 25, 1997, at around 6:00 a.m., Dionesio Inguito, Sr. was driving his motorcycle with his two minor children, Dionesio Inguito, Jr. and Cherry Inguito, towards school along a curving road in Barangay Kiara, Don Carlos, Bukidnon.
- Rogelio J. Gonzaga was driving a Toyota Land Cruiser descending the same road from the opposite direction but occupying the same lane as the motorcycle.
- Dionesio Sr. signaled Rogelio by blowing his horn to return to his proper lane, but Rogelio did not comply.
- Attempting to avoid collision, Dionesio Sr. swerved left; Rogelio's vehicle also swerved in the same direction, causing a head-on collision.
- The collision threw Dionesio Sr. and his children off the motorcycle; Dionesio Sr. was pinned beneath the Land Cruiser, while Cherry and Dionesio Jr. sustained leg injuries.
- Siblings Rolf, Cherry, and Jenny Ann Aquino, traveling on the same road, stopped to assist, with Rolf seeking additional help and eventually getting Kagawad Nerio Dadivas, who transported the injured to the hospital.
- Medical treatment included operations on Dionesio Sr. and Jr.; Dionesio Sr. died from injuries, while Cherry and Dionesio Jr. remained hospitalized for over a month.
- All medical and related expenses were borne by Clemencia Inguito, Dionesio Sr.’s wife.
Charges and Trial Proceedings
- Rogelio was charged with Reckless Imprudence Resulting to Homicide with Double Serious Physical Injuries and Damage to Property under Article 365 in relation to Article 263 of the Revised Penal Code.
- The Information included an aggravating circumstance alleging Rogelio failed to render immediate assistance to the injured.
- Rogelio pleaded not guilty and asserted he was driving on his proper lane and stopped the vehicle when he saw motorcycles approaching recklessly but was still hit by Dionesio Sr.’s motorcycle.
- He claimed he assisted in retrieving the pinned victims using a jack handle and attempted to bring them to the hospital; however, his vehicle’s brakes were defective, necessitating another vehicle's use.
Regional Trial Court (RTC) Decision
- The RTC, in a decision dated July 31, 2006, found Rogelio guilty beyond reasonable doubt, holding that his excessive speed and driving on the wrong side of the road directly caused the collision and resulting injuries and death.
- Rogelio was sentenced to an indeterminate penalty: four years, two months of prision correccional as minimum to eight years and one day of prision mayor as maximum.
- Civil liabilities were imposed totaling P425,000 for moral damages for death and mental anguish, medical expenses, wake and burial costs, damaged motorcycle, loss of earning capacity,