Case Summary (G.R. No. 136266)
Key Dates and Applicable Law
Decision Date: March 8, 1922
Governing Charter: Organic Act of 1902 and Jones Law (Act of Congress, August 29, 1916)
Statutory Instrument in Question: Act No. 2886 (amending Section 2 of General Orders No. 58, series of 1900)
Facts and Trial Court Findings
While operating an automobile at approximately 30 mph on a six-meter-wide highway, appellant attempted to pass between a stationary wagon and a pile of stones. He failed to reduce speed or exercise the care expected of a prudent driver, causing his vehicle to strike and instantly kill the young boy. The trial court concluded that appellant’s conduct constituted homicide by reckless negligence, a finding fully supported by the evidence.
Procedural History and Assignments of Error
Appellant was charged under Act No. 2886 for homicide by reckless negligence and sentenced to one year and one day of prisión correccional plus costs. He appealed, presenting four main errors:
- Challenge to Act No. 2886 as unconstitutional and void for lack of jurisdiction;
- Claim that prosecution under the Act deprived him of due process;
- Assertion of lack of jurisdiction over his person and the subject matter;
- Contention that the conviction and sentence were erroneous on the merits.
Constitutional and Statutory Authority over Criminal Procedure
The Court analyzed whether criminal procedure in the Philippines was governed by constitutional enactment or ordinary statute. It held that, in line with U.S. precedents, procedural rules are enacted by legislature under its police power, not by constitution. The Philippine Legislature, as successor to the U.S. Military Government and Philippine Commission, possesses plenary authority—granted by the Organic Act and the Jones Law—to define, amend, and repeal criminal procedure.
Nature of General Orders No. 58 and Amendments Thereto
General Orders No. 58 was promulgated by the U.S. Military Government in 1900 to amend pre-existing criminal procedure. It explicitly had “the force and effect of law” but did not possess constitutional status. Act No. 2886 amended Section 2 to change the prosecuting party’s designation from “United States” to “People of the Philippine Islands.” Because General Orders No. 58 is statutory, such amendments fall squarely within legislative competence.
Delegation of Sovereign Power and Autonomy of Philippine Government
The Court underscored that the power to prosecute crimes is an attribute of sovereignty and, by virtue of congressional enactments, has been delegated to the Philippine legislative and executive branches. The autonomy of the territorial government extends to judicial actions, including criminal prosecutions in its own name—akin to the practices in Puerto Rico and Hawaii.
Form of Criminal Complaints and Constitutional Guarantees
The Court affirmed that legislatures may prescribe the form of indictments and informations as long as the accused’s right to be informed of the nature and cause of the accusation is preserved. The substitution of the “People of the Philippine Islands” in the complaint’s caption does not infringe due process or the accused’s constitutional rights.
Congressional Acquiescence to Territorial Legislation
Under both the Organic Act and Jones Law, all Philipp
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Facts of the Case
- The appellant, Gregorio Santiago, was operating an automobile on a public highway measuring six meters in width.
- He drove at a speed of thirty miles per hour, attempting to pass between a stationary wagon and a heap of stones.
- Two young boys were present in the narrow space; Santiago failed to slow down or exercise the care expected of a reasonably prudent person.
- His automobile struck and instantly killed seven-year-old Porfirio Parondo.
Procedural History
- Santiago was prosecuted for homicide by reckless negligence under Act No. 2886 of the Philippine Legislature.
- The trial court found him guilty, sentencing him to one year and one day of prision correccional and to pay trial costs.
- Santiago appealed to the Supreme Court of the Philippines, claiming four errors by the trial court.
Issues on Appeal
- Whether the trial court should have taken judicial notice that Act No. 2886 is unconstitutional and divests it of jurisdiction.
- Whether the complaint should have been dismissed because Act No. 2886 violates due process.
- Whether the court a quo lacked jurisdiction over the person of the accused and the subject-matter.
- Whether the trial court erred in finding Santiago guilty and in imposing sentence and costs.
Supreme Court’s Review of Facts
- The Supreme Court examined the record and found the trial judge’s factual findings “well-written” and fully supported by evidence.
- No reasonable doubt existed that the appellant failed to slow his automobile or exercise due care, directly causing the boy’s death.
Constitutional Challenge to Act No. 2886
- Act No. 2886 amended Section 2 of General Orders No. 58 to substitute “People of the Philippine Islands” for “United States” as the plaintiff in criminal prosecutions.
- The appellant argued the Philippine Legislature lacked authority to amend a provision possessing the character of “c