Case Summary (G.R. No. 210129)
Factual Background
On October 14, 2004, Ursicio Arambala, while riding his motorcycle on Roxas Street in Pagadian City, collided with a multicab driven by S/Sgt. Cornelio Paman. Arambala was thrown from his motorcycle, suffering serious injuries that required medical attention at multiple hospitals. A case for reckless imprudence resulting in serious physical injuries was filed against Paman, who pleaded not guilty.
Initial Court Proceedings
The Municipal Trial Court in Cities (MTCC) found Paman guilty of the charges and sentenced him to imprisonment. However, on appeal, the Regional Trial Court (RTC) overturned this conviction, concluding that Arambala was at fault for the accident, as he had the opportunity to avoid the collision.
Certiorari Petition by the Prosecution
Dissatisfied with the RTC's decision, the City Prosecutor filed a motion for reconsideration, which was denied. Subsequently, the Office of the Solicitor General (OSG) filed a petition for certiorari, alleging that the RTC judge had committed grave abuse of discretion in exonerating Paman.
Court of Appeals Ruling
On July 4, 2013, the Court of Appeals (CA) granted the OSG's petition, reinstating Paman's conviction and adjusting the penalty. The CA asserted that the RTC had erred in finding Arambala at fault and emphasized that the collision primarily resulted from Paman driving on the wrong side of the road.
Petition for Review by Paman
Paman sought a reconsideration of the CA’s ruling, disputing the appropriateness of the certiorari petition against his acquittal. He argued that the prosecution's evidence was insufficient and reiterated that Arambala was responsible for the accident.
Supreme Court's Position on Certiorari
The Supreme Court rejected Paman's assertions and affirmed that a certiorari petition is indeed the appropriate legal remedy in cases of acquittal. This court underscored the finality-of-acquittal doctrine while noting that exceptions can be made under specific circumstances revealing grave abuse of discretion as warranted by the evidence of the case.
Findings of the Supreme Court
The court determined that the RTC had gravely abused its discretion by ignoring substantial evidence that indicated Paman's liability. The CA had correctly established that Paman was at fault for violating traffic regulations and driving recklessly.
Determination of Liability
The Supreme Court found that Paman failed to uphold his duty to drive with due diligence and care. It
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Case Reference
- Jurisprudence: 813 Phil. 139
- Court: Third Division
- G.R. No. 210129
- Date: July 05, 2017
Background of the Case
- The case involves a petition for review on certiorari filed by S/Sgt. Cornelio Paman against the People of the Philippines.
- The petition seeks to annul the Decision dated July 4, 2013, and Resolution dated October 30, 2013, issued by the Court of Appeals in CA-G.R. SP No. 04542.
Incident Description
- On October 14, 2004, at approximately 1:20 p.m., Ursicio Arambala was riding a motorcycle on Roxas Street, Pagadian City.
- As he neared the intersection with Broca Street, a multicab driven by S/Sgt. Cornelio Paman collided with him.
- The impact caused Arambala to be thrown from his motorcycle, striking his head on the pavement.
- Witness Emilda Salabit observed the incident and assisted in getting Arambala to the hospital.
Medical Findings
- A Computed Tomography Scan revealed that Arambala suffered from a cerebral hematoma.
- Arambala was hospitalized on October 15, 2004, and later readmitted on October 24, 2004, due to complications arising from the initial injuries.
Criminal Proceedings
- On February 21, 2005, an Information for reckless imprudence resulting in serious physical injuries was filed against Paman.
- Paman pleaded not guilty during the proceedings.
- On February 11, 2010, the Municipal Trial Court in Cities (MTCC) convicted Paman and sentenced him to imprisonment.
Appeal to Regional Trial Court
- Paman appealed the conviction to the Regional Trial Court (RTC) of San Miguel, Zamboanga del Sur.
- On July 12, 2011, the RTC rev