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)

Applicable Law (1987 Constitution; statutory provisions relied upon)

Constitutional basis: 1987 Constitution (decision rendered 2022).
Penal statutes and rules cited in the resolution: Article 365, Revised Penal Code (RPC) as amended by R.A. No. 10951 (imprudence and negligence and penalties); Article 266 RPC (slight physical injuries); Article 48 RPC (complex crimes) — discussed as inapplicable to quasi‑crimes under Article 365; Article 2185, New Civil Code (presumption of negligence); Article 2224, New Civil Code (temperate damages); Sections of R.A. No. 4136 (Land Transportation and Traffic Code) — e.g., Sec. 41 (overtaking rule), Secs. 35 and 37 (speed and overtaking duties). Remedies and civil indemnity principles and prevailing jurisprudence (Ivler, De los Santos, Angeles, Reodica and others) were extensively considered.

Facts of the incident (prosecution and defense versions)

Prosecution: Petitioner overtook another vehicle and encroached into the jeepney’s lane, colliding with a jeepney driven by Rico Mendoza; the collision caused a deep forehead laceration and cervical strain to Rico (hospitalization and suturing), injuries to Leilani and Myrna, and substantial damage to the jeepney (estimated repair cost P350,000). The incident occurred around 3:00 a.m., on a poorly lighted road, and petitioner was allegedly speeding.
Defense: Petitioner claimed he and his 13‑year‑old son were returning from a late‑night gathering; the jeepney allegedly veered into petitioner’s lane and hit the Delica; petitioner and his son were also injured and treated at Sacred Heart Medical Center; he denied overtaking in the negligent manner alleged.

Trial evidence, factfinding and initial trial court disposition (MTCC)

The MTCC credited the prosecution witnesses (Rico, Leilani, Myrna) and the Traffic Accident Report and Sketch Plan indicating point of impact on the jeepney’s lane. MTCC found petitioner’s overtaking without requisite precautions and speeding to be the proximate cause of injuries and damage; it convicted petitioner of reckless imprudence resulting in multiple physical injuries and damage to property and imposed an indeterminate imprisonment (one month and twenty‑one days to two months) and ordered indemnities (hospitalization expenses, lost income awards, moral damages, and P350,000 for repair of the jeepney).

RTC and Court of Appeals rulings and modifications

RTC: Affirmed MTCC’s factual findings and conviction, emphasizing the sketch and the petitioner’s encroachment into the jeepney’s lane.
Court of Appeals (CA): Affirmed guilt but modified penalties and awards. CA concluded injuries amounted to slight physical injuries and imposed a straight penalty of two months and one day of arresto mayor (finding application of Section 97 R.A. No. 10951 and characterizing the injuries as less grave felony — a point later corrected by the Supreme Court). CA deleted unproven lost income awards, replaced some awards with temperate damages (P8,000 to spouses Rico and Leilani; P2,000 to Myrna) and reduced the jeepney repair award to temperate damages of P150,000 given lack of proof of actual repair expenditure. CA denied petitioner’s motion for reconsideration.

Issue presented to the Supreme Court

Whether the Supreme Court should uphold petitioner’s conviction for Reckless Imprudence Resulting in Damage to Property and Multiple Physical Injuries and whether the penalties and damages imposed by the courts a quo were correct.

Supreme Court’s factual determinations and legal prerequisites for conviction

The Supreme Court en banc affirmed the courts a quo factual findings: petitioner voluntarily and without malice executed an overtaking maneuver without requisite precautions, encroached upon the oncoming lane, and thereby caused material damage and physical injuries. The Court reiterated the elements of reckless imprudence under Article 365 RPC and applied Sec. 41 of R.A. No. 4136 and Article 2185, New Civil Code (presumption of negligence) — petitioner failed to rebut the presumption. The doctrine of last clear chance was held inapplicable because the records established petitioner’s negligence as the proximate cause.

Ivler doctrine, Article 48 vs. Article 365 — treatment of quasi‑crimes

The Court reaffirmed Ivler v. Modesto‑San Pedro: reckless imprudence under Article 365 is a quasi‑crime distinct from intentional felonies and is not merely a modality of committing crimes; Article 48 (complex crime doctrine) is inapplicable to quasi‑crimes. The Court explicitly abandoned People v. De los Santos insofar as it treated reckless imprudence as susceptible to complexing under Article 48. The correct procedure is a single information alleging reckless imprudence and all its consequences, with the court imposing appropriate penalties for each consequence according to Article 365’s scheme rather than applying Article 48 complexing rules.

Penalty classification under Article 365 and its application to the case

Article 365 prescribes graduated penalties depending on what the act would have constituted if intentional (grave, less grave, or light felony). The Court found certificates of confinement and medical evidence showed the victims sustained slight physical injuries (light felony if intentional) — not less grave injuries. Consequently, the Court determined the proper criminal penalties under Article 365: reckless imprudence resulting in a light felony is punishable by arresto menor in its maximum period (21–30 days). Because the penalty that would have applied had the act been intentional (Article 266 for slight physical injuries) is equal to or lower than the Article 365 penalty, the statute directs imposition of the penalty next lower in degree — public censure. Therefore, the Supreme Court imposed public censure for each of the three slight physical injuries (Rico, Leilani, Myrna).

Damage to property, temperate damages and fine imposed

The CA and the Supreme Court agreed the jeepney was damaged, but the prosecution failed to prove the actual expense of repair; the vehicle work order showed only an estimate (P350,000) without proper authentication. Under Article 2224, New Civil Code, temperate damages are appropriate when pecuniary loss is shown but amount cannot be established with certainty; the Court found P150,000 reasonable as temperate damages for the owner, Noel G. Garcia. Separately, the Court (majority) applied the third paragraph of Article 365 and imposed a criminal fine equal to P150,000 as the penalty for resulting damage to property (the majority view); all monetary awards (temperate damages and fine) bear legal interest at 6% pe

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