Case Summary (G.R. No. 139603)
Facts and Circumstances of the Incident
On the evening of September 12, 1999, Ferdinand de Leon was driving his jeepney in Barangay Engkanto, Angat, Bulacan with his family. Reynaldo Mariano was driving a red Toyota pick-up truck in the same vicinity. The petitioner overtook Ferdinand’s jeep, almost causing a collision. Ferdinand then blocked the path of Mariano’s vehicle, had a verbal altercation with him, which eventually de-escalated. After parting ways, Ferdinand parked his jeep outside his mother’s house and alighted. He was subsequently struck by Mariano’s overtaking pick-up, causing severe injuries which required prolonged hospitalization and medical treatment. Mariano surrendered at the police camp after the incident.
Lower Courts’ Rulings on Liability and Penalty
The Regional Trial Court (RTC) convicted Mariano of frustrated homicide, citing the presence of evident premeditation, treachery, and abuse of superior strength, and sentenced him to an indeterminate term of imprisonment under Article 249 of the RPC, along with damages. On appeal, the Court of Appeals (CA) reclassified the offense as reckless imprudence resulting in serious physical injuries under Article 365 of the RPC and reduced the penalty and damages imposed.
Supreme Court’s Affirmation of Liability for Reckless Imprudence
The Supreme Court upheld the CA’s finding that Mariano was guilty of reckless imprudence resulting in serious physical injuries. The petitioner's claim of the incident being an accident and the absence of criminal intent was rejected. Evidence showed that Mariano was driving at a high speed to overtake Ferdinand’s jeep, which resulted in the victim being hit and severely injured. The Court emphasized that a prudent driver must operate a vehicle at a reasonable speed and exercise due care to avoid harm to others, considering all circumstances. The petitioner’s acquaintance with the victim and the environment imposed a duty to foresee and avoid such risks.
Legal Standard for Reckless Imprudence and Its Application
Reckless imprudence is defined as a voluntary act lacking malice but characterized by culpable carelessness or failure to exercise necessary precautions, resulting in material damage. To constitute reckless imprudence, the act must be a willful or wanton disregard of probable consequences, not a mere slip or inattention. The Court noted that Mariano’s high speed and overtaking maneuver demonstrated such culpable disregard. The proximate cause of Ferdinand’s injuries was the petitioner’s imprudent driving.
Mitigating Circumstances and Penalty Imposition
The Court explained that voluntary surrender is not an absolute mitigating circumstance for reckless imprudence, as the circumstances and degree of negligence must be considered with judicial discretion. Moreover, the CA had erred in imposing a penalty corresponding to a grave felony, which the petitioner’s conduct would have constituted if intentional. Based on the actual injuries sustained by Ferdinand, which incapacitated him for over 90 days but did not seriously impair his faculties, the offense falls under less grave felonies with corresponding correctional penalties.
Correct Penalty for Reckless Imprudence Resulting in Serious Physical Injuries
Applying Article 365 of the Revised Penal Code, recognizing the gravity of injuries under Article 263 (3) of the RPC, the Court held the appropriate penalty to be arresto mayor in its minimum and medium periods, ranging from one to four months. Given the absence of aggravating circumstances and the limited maximum duration of imprisonment, the Indeterminate Sentence Law did not apply, justifying the imposition of a straight penalty of two months of arresto mayor.
Damages Award and Interest
The Court affirmed the CA’s reduced award of actual damages at P58,402.75 after accounting for an earlier P50,000.00 financial assistance already provided by Mariano. This amount was supported by receipts and other competent evidence proving the medi
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Case Syllabus (G.R. No. 139603)
Facts and Background
- The petitioner, Reynaldo S. Mariano, was charged with frustrated murder by the Office of the Provincial Prosecutor of Bulacan for having deliberately hit and run over Ferdinand de Leon using a motor vehicle, with the crime allegedly committed on September 12, 1999 in Angat, Bulacan.
- The incident involved the petitioner overtaking the jeepney driven by Ferdinand de Leon, which led to a vehicle collision resulting in serious injuries to De Leon.
- Prior to the accident, an altercation occurred after the petitioner overtook the jeep, which angered De Leon, who then blocked the petitioner’s path and confronted him; however, the situation was temporarily pacified by a family member.
- De Leon did not proceed directly home but stopped at his mother’s house where he was struck by the petitioner’s pick-up truck and thrown approximately four meters, losing consciousness.
- Medical evidence showed De Leon suffered multiple facial injuries, a fracture of the orbital wall, and subdural hemorrhage secondary to severe head trauma.
- De Leon incurred significant medical expenses amounting to over Php 86,000 at two hospitals, additional payments for medicines, scanning, doctor’s fees, caregiver services, and masseur fees totaling several more thousands.
- Petitioner voluntarily surrendered at Camp Alejo S. Santos, indicating some degree of responsibility.
- An initial financial assistance payment of Php 50,000 was made by the petitioner to De Leon.
Trial Court Decision
- The Regional Trial Court (RTC), after a full trial, convicted the petitioner of frustrated homicide, finding intentional and malicious conduct on his part.
- The RTC sentenced petitioner to an indeterminate penalty ranging from 3 years 4 months of Prision Correccional (minimum) to 6 years 1 day of Prision Mayor (maximum).
- The court awarded the complainant actual damages of Php 196,043.25 (minus the Php 50,000 already paid), moral damages of Php 100,000, and costs of suit.
Court of Appeals Decision
- On appeal, the Court of Appeals (CA) revised the conviction, downgrading the crime to reckless imprudence resulting in serious physical injuries rather than frustrated homicide.
- The CA imposed an indeterminate penalty of 2 months 1 day Arresto Mayor (minimum) to 1 year 7 months 11 days Prision Correcci