Case Summary (G.R. No. L-25366)
Background of the Case
The initial charge against Buan was for slight physical injuries through reckless imprudence, filed in the Justice of the Peace Court of Guiguinto. Buan was acquitted of these charges on December 16, 1963. Subsequently, the Provincial Fiscal of Bulacan filed a new information in the Court of First Instance for serious physical injuries and damage to property through reckless imprudence, based on the same highway collision.
Legal Issue
The central legal issue presented in this case is whether Buan's subsequent prosecution for serious physical injuries and damage to property constitutes double jeopardy, as he had already been acquitted of the related charge of slight physical injuries. Buan's defense contended that moving forward with the second case placed him at risk of being tried for the same offense twice, which is prohibited under the principles of double jeopardy.
Legal Analysis of Double Jeopardy
The court determined that Buan's acquittal of slight physical injuries effectively barred the subsequent prosecution for serious physical injuries arising from the same incident. The court referenced Article 365 of the Revised Penal Code, which states that the penalization for an act of reckless imprudence is based on the negligent act itself rather than the outcomes of that act. Hence, regardless of the degree of injury sustained by the victims, the negligent act that led to the injuries constitutes a singular offense referable to the same reckless behavior.
Jurisprudence and Precedents
The court relied on both local and Spanish jurisprudence, highlighting several relevant rulings including:
- In People v. Silva, the dismissal of a slight physical injuries charge barred subsequent prosecution for homicide related to the same act of recklessness.
- Similar conclusions were reached in People v. Diaz and People v. Belga, where charges stemming from the same set of facts could not be split for separate prosecution.
The decision reflects the established principle that the essence of criminal negligence encompasses singular negligent actions resulting in varying consequences, thereby limiting prosecution to one action regardless of the numbe
...continue readingCase Syllabus (G.R. No. L-25366)
Case Background and Procedural History
- The accused-appellant, Jose Buan, was driving a passenger bus of the La Mallorca Company on July 23, 1962, along MacArthur Highway in Guiguinto, Bulacan.
- Due to alleged negligence and recklessness, the bus collided with a passenger jeep owned by Sergio Lumidao, resulting in the jeep overturning and causing injuries to its passengers as well as property damage.
- Injuries sustained included six passengers with slight physical injuries requiring 5 to 9 days of medical attention, and three passengers with serious injuries necessitating 30 to 45 days of medical care.
- The jeep suffered property damage amounting to P1,395.00.
- Initially, the accused was charged with slight physical injuries through reckless imprudence before the Justice of the Peace Court of Guiguinto and was acquitted on December 16, 1963.
- Before this acquittal, the Provincial Fiscal filed a second information for serious physical injuries and damage to property through reckless imprudence in the Court of First Instance of Bulacan.
- The accused’s counsel filed a motion to quash the second charge on double jeopardy grounds, arguing that the acquittal barred the second prosecution.
- The Court of First Instance denied the motion, prompting a direct appeal to the Supreme Court.
Legal Issue
- Whether the second prosecution for serious physical injuries and damage to property through reckless imprudence after the accused’s acquittal for slight physical injuries through reckless imprudence constitutes double jeopardy, thereby barring the second case.
Supreme Court’s Ruling on Double Jeopardy
- The Supreme Court ruled in favor of the accused-appellant, holding that the second prosecution indeed placed the accused twice in jeopardy for the same offense.
- The Court emphasized that once an accused has been adjudged either guilty or not guilty of a specific reckless imprudence act, further prosecution for that same act, regardless of the severity of its consequences, is barred.
- The cornerstone of criminal negligence under