Title
Morales vs. People
Case
G.R. No. 240337
Decision Date
Jan 4, 2022
Petitioner convicted of reckless imprudence for overtaking without ensuring road clearance, causing collision, injuries, and property damage; penalties and damages affirmed with modifications.

Case Summary (G.R. No. 240337)

Petitioner and Respondent

Petitioner Morales was charged with reckless imprudence resulting in damage to property and multiple physical injuries. The People of the Philippines prosecuted the case through witnesses and documentary evidence.

Key Dates

  • May 14–15, 2013: Vehicular accident between petitioner’s Delica van and private complainants’ jeepney
  • June 5, 2013: Information filed by the State
  • June 30, 2015: MTCC conviction and sentencing
  • December 1, 2016: RTC affirmed MTCC decision
  • March 15, 2018: CA affirmed with modifications
  • June 22, 2018: CA denied reconsideration
  • September 21, 2020: Supreme Court resolution denying relief
  • January 4, 2022: En banc resolution on motion for reconsideration

Applicable Law

  • 1987 Philippine Constitution: Due process, right against double jeopardy
  • Revised Penal Code (RPC) Article 365: Defines and penalizes reckless imprudence resulting in damage to property and/or physical injuries
  • Land Transportation and Traffic Code (R.A. No. 4136), Sections 35 & 41: Speed limits and rules on overtaking
  • New Civil Code Article 2185: Presumption of negligence in traffic accidents
  • Rules on civil indemnity and temperate damages (Civil Code, Article 2224)

Facts of the Case

On May 15, 2013 at around 3:00 a.m., petitioner drove his Delica van on Sto. Rosario Street, Angeles City. He attempted to overtake a vehicle without ensuring the opposite lane was clear and swerved into the lane occupied by an Isuzu jeepney driven by Rico Mendoza with passengers Leilani Mendoza, Myrna Cunanan, and Albert Vital. The collision caused slight physical injuries to three occupants, serious injury to the driver, and damage to the jeepney valued at an estimated ₱350,000.

MTCC Decision

The MTCC of Angeles City found petitioner guilty of reckless imprudence resulting in multiple physical injuries and damage to property. He was sentenced to an indeterminate term of one month and twenty-one days to two months’ imprisonment and ordered to pay:

  1. Hospital and related expenses and lost income for spouses Rico and Leilani Mendoza, and Myrna Cunanan
  2. Moral damages to the Mendoza spouses and Myrna
  3. Hospital expenses of Albert Vital
  4. Repair cost of ₱350,000 to owner Noel G. Garcia

RTC and CA Proceedings

The RTC affirmed the MTCC’s findings and penalties. The CA likewise upheld petitioner’s conviction but modified the penalty to a straight term of two months and one day of arresto mayor. It deleted awards for lost income and reduced damages for property repair to temperate damages of ₱150,000, as well as temperate damages of ₱8,000 and ₱2,000 for the Mendoza spouses and Myrna, respectively.

Issues Presented

Whether petitioner’s conviction for reckless imprudence resulting in damage to property and physical injuries should be upheld and whether the penalty and damages awards were properly imposed.

Supreme Court’s Analysis

  1. Elements of Reckless Imprudence (RPC Art. 365): voluntary act without malice, resulting material damage through inexcusable lack of precaution.
  2. Traffic Regulation Violation: petitioner overtook on the left without ensuring a clear view of oncoming traffic (R.A. 4136, Secs. 35 & 41).
  3. Presumption of Negligence: under Civil Code Article 2185, since petitioner violated a traffic rule, negligence was presumed and unrebutted.
  4. Complex Crimes and Quasi-crimes: affirmed Ivler doctrine—Article 48 (complex crimes) does not apply to quasi-offenses under Article 365; only one information may be filed regardless of consequences.
  5. Classification of Injuries: Certificates of Confinement showed physical injuries were slight; slight physical injuries under RPC Article 266 are light felonies.
  6. Penalty Determination (RPC Art. 365):
    – Reckless imprudence resulting in slight physical injuries (light felony) warrants arresto menor in its maximum period (21–30 days).
    – Since the penalty equals that for intentional slight physical injuries, the penalty next lower in degree (public censure) applies.
  7. Damage to Property: lack of proof of actual repair cost justified temperate damages of ₱150,000. Fine for property damage under Article 365 (fine from the value of damage to three times i

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