Case Summary (G.R. No. 172716)
Facts
In August 2004, a vehicular collision injured Evangeline Ponce and killed her husband, Nestor C. Ponce, while damaging the Ponce vehicle. Aguilar was charged in MeTC Br. 71 with:
- RC 82367 – Reckless Imprudence Resulting in Slight Physical Injuries (victim: Evangeline Ponce)
- RC 82366 – Reckless Imprudence Resulting in Homicide and Damage to Property (victims: Nestor Ponce and property)
On September 7, 2004, Aguilar pleaded guilty to RC 82367 and received public censure. He then moved to quash RC 82366 on double jeopardy grounds; the MeTC denied the motion.
Procedural History
– Aguilar filed SCA No. 2803 in RTC Br. 157 to review the MeTC’s refusal to quash RC 82366.
– He sought suspension of arraignment; MeTC arraigned him in absentia on May 17, 2005, forfeited bail, and ordered his arrest.
– MeTC later denied suspension and postponed arraignment until after arrest; Aguilar’s reconsideration remained unresolved.
– Ponce moved in RTC to dismiss SCA No. 2803 for loss of standing; RTC dismissed the petition on February 2 and May 2, 2006.
– Aguilar petitioned the Supreme Court under Rule 45.
Issues
- Did Aguilar’s non-appearance at arraignment in RC 82366 divest him of standing to prosecute SCA No. 2803?
- If standing remained, does the Double Jeopardy Clause bar continued prosecution in RC 82366?
Standing to Maintain the Petition
The Court held that rules dismissing appeals for bail-jumping (R.R. Crim. P. 124, Sec. 8; R.R. Crim. P. 125) apply only to appeals of convictions, not to pre-trial special civil actions. Under Rule 114, Sec. 21, non-appearance at a post-arraignment hearing subjects the accused’s bondsmen to potential liability but does not strip the accused of standing; trial in absentia is permissible. Aguilar’s failure to appear while his motion to suspend proceedings was pending did not convert him into a fugitive or extinguish his personality to pursue SCA No. 2803. The RTC therefore erred in dismissing the petition for want of standing.
Double Jeopardy and Reckless Imprudence
Invoking the 1987 Constitution’s Double Jeopardy Clause (Art. III, Sec. 21) and Revised Rules of Criminal Procedure (Rule 117, Sec. 7), the Court reaffirmed that “reckless imprudence” under RPC Art. 365 is a single quasi-offense defined by the mental attitude of negligence; the various harms it causes (death, injury, property damage) affect only the penalty. This concept dates to Quizon v. Justice of the Peace (1955) and is firmly entrenched in the constant line of decisions (Diaz, Belga, Silva, Buan, Buerano) barring successive prosecutions for different resulting acts arising from the same reckless conduct. The Court rejected application of RPC Art.
Case Syllabus (G.R. No. 172716)
Facts
- In August 2004, a vehicular collision gave rise to two separate MeTC complaints against petitioner Jason Ivler y Aguilar:
- Criminal Case No. 82367: Reckless Imprudence Resulting in Slight Physical Injuries to Evangeline Ponce.
- Criminal Case No. 82366: Reckless Imprudence Resulting in Homicide (death of Nestor C. Ponce) and Damage to Property (vehicle of the Ponces).
- Petitioner posted bail and, on September 7, 2004, pleaded guilty to Criminal Case No. 82367, receiving public censure.
- Invoking double jeopardy, petitioner moved to quash Criminal Case No. 82366; the MeTC refused, ruling the two offenses distinct.
- Petitioner filed S.C.A. No. 2803 before the RTC of Pasig (Branch 157) challenging the MeTC’s refusal; concurrently he sought suspension of the MeTC proceedings in Case No. 82366.
- Without acting on the suspension motion, the MeTC arraigned petitioner in absentia on May 17, 2005, cancelled bail and ordered his arrest.
- The MeTC later denied the suspension motion and fixed arraignment after arrest; petitioner’s reconsideration remained unresolved at the time of this petition.
- Relying on the MeTC arrest order, respondent Ponce moved in the RTC to dismiss S.C.A. No. 2803 for forfeiture of standing; petitioner contested.
Ruling of the Trial Court
- RTC, Branch 157, by Order of February 2, 2006, dismissed S.C.A. No. 2803.
- Ground: petitioner lost personality to maintain the petition upon MeTC’s warrant for his arrest.
- Merits of double jeopardy claim were not reached.
- Reconsideration motion was denied in Order of May 2, 2006.
Issues Presented
- Whether petitioner forfeited standing to pursue S.C.A. No. 2803 due to non-appearance and MeTC arrest order.
- If standing was not forfeited, whether the Double Jeopardy Clause bars further prosecution in Criminal Case No. 82366.