Case Summary (G.R. No. 125066)
Procedural History and Charges
The RTC convicted Reodica on 31 January 1991 and sentenced her to six months imprisonment (arresto mayor) and ordered her to pay ₱13,542 corresponding to car repairs and medical expenses. The Court of Appeals (CA) affirmed this decision on 31 January 1996 and denied her motion for reconsideration in May 1996. Petitioner then filed a petition for review on certiorari under Rule 45 of the Rules of Court, asserting errors in penalty imposition, treatment of multiple offenses as a complex crime, jurisdiction, and prescription.
Applicable Law and Penalty Determination
Article 365 of the Revised Penal Code (RPC) governs reckless imprudence. It prescribes varying penalties depending on the gravity the resulting offense would have had if intentional. Generally, reckless imprudence causing slight physical injuries (a light felony) is penalized by arresto menor (21-30 days), while reckless imprudence causing damage to property (a less grave felony in this instance) is penalized by arresto mayor in its minimum and medium periods (1 month and 1 day to 4 months). The trial court erred in imposing arresto mayor for the physical injury, which should not have merited such a penalty. Furthermore, by application of Article 71 of the RPC regarding graduated penalties, the penalty for slight physical injuries by reckless imprudence is public censure, the penalty next lower than arresto menor.
Classification of Offenses
The offense of reckless imprudence resulting in slight physical injuries is classified as a light felony, since it is punishable by a light penalty (public censure/arresto menor). The offense of reckless imprudence causing damage to property, punishable by arresto mayor, is a less grave felony. Hence, the two offenses differ in classification and penalty.
Applicability of Complex Crime Doctrine
Article 48 of the RPC permits treatment of multiple felonies arising from a single act as a complex crime when all are grave or less grave felonies, imposing the penalty for the most serious offense at maximum period. However, where one offense is a light felony, as here, Article 48 does not apply. The offenses of reckless imprudence resulting in damage to property and physical injuries, as light and less grave felonies respectively, do not constitute a complex crime and must be charged separately.
Duplicity of the Information and Waiver
Petitioner could have challenged the defect of charging two offenses in one information (duplicity) before pleading to the charge through a motion to quash. Her failure to do so results in waiver of this issue, precluding raising it for the first time on appeal.
Jurisdiction of the RTC
At the time of filing, jurisdiction depended on the penalty prescribed. Offenses punishable by imprisonment not exceeding four years and two months fall under the exclusive jurisdiction of Metropolitan, Municipal, and Municipal Circuit Trial Courts (MeTCs, MTCs, MCTCs). Since the offenses charged involved penalties not exceeding arresto mayor (maximum four months), these lower courts had jurisdiction. The RTC lacked jurisdiction to hear the case; thus, the proper procedure was filing in the lower court corresponding to the penalties involved.
Prescription of the Offenses
Reckless imprudence causing slight physical injuries (light felony) prescribes in two months; reckless imprudence resulting in damage to property (less grave felony) prescribes in five years under Article 90 of the RPC. However, the filing of a complaint with the Fiscal’s Office three days after the incident interrupted the prescriptive period pursuant to Article 91, which provides that prescription is suspended by the filing of a complaint or information. This interruption continues until termination of proceedings. The petitioner’s claim of prescription is unfounded as the complaint was timely filed following the accident.
Final Ruling
The Supreme Court set aside the Court of Appeals decision because the RTC had no jurisdiction over the case. The case
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Case Syllabus (G.R. No. 125066)
Factual Background and Procedural History
- On October 17, 1987, petitioner Isabelita Reodica was driving a van along Doña Soledad Avenue, Better Living Subdivision, Parañaque, Metro Manila.
- Due to alleged recklessness, her vehicle collided with the car of complainant Norberto Bonsol, resulting in slight physical injuries and property damage amounting to ₱8,542.00.
- Bonsol filed an Affidavit of Complaint three days after the incident on October 20, 1987.
- On January 13, 1988, an information was filed against petitioner before the Regional Trial Court (RTC) of Makati, docketed as Criminal Case No. 33919, charging her with the quasi-offense of reckless imprudence resulting in damage to property with slight physical injuries.
- Petitioner pleaded not guilty; trial ensued.
- On January 31, 1991, the RTC convicted her and sentenced her to six months of arresto mayor imprisonment and awarded damages amounting to ₱13,542.00 (₱8,542.00 for car repair and ₱5,000.00 for medical expenses).
- Trial court justified the imposition of arresto mayor due to the infliction of slight physical injuries by recklessness.
- Petitioner appealed to the Court of Appeals (CA), which affirmed the RTC decision on January 31, 1996.
- Petitioner filed a motion for reconsideration raising issues of excessive penalty, lack of jurisdiction, and prescription; CA denied the motion on May 24, 1996.
- Petitioner brought the case to the Supreme Court by a petition for review on certiorari under Rule 45.
Issues Raised in the Petition
- Whether the penalty of six months arresto mayor imposed on petitioner was correct.
- Whether reckless imprudence resulting in slight physical injuries and reckless imprudence resulting in damage to property are light felonies.
- Whether the offenses involved constitute one complex crime under Article 48 of the Revised Penal Code (RPC).
- Whether the duplicity of the information could be questioned on appeal.
- Whether the RTC had jurisdiction over the offenses.
- Whether the offenses had already prescribed before filing of information.
Pertinent Facts on the Incident and Proceedings
- The collision caused slight physical injuries requiring less than nine days of medical care and loss of capacity to work.
- The vehicle damage cost amounted to ₱8,542.00.
- The information accused petitioner of willfully, recklessly, negligently, and imprudently driving her vehicle in violation of traffic laws causing the accident.
- Petitioner sought to withdraw her appeal and requested probation, which the CA denied.
- Petitioner argued that penalty was excessive due to misquotation of People v. Aguilar as "Aguiles," where the penalty was arresto menor, not arresto mayor.
- She also contended the two offenses should have been charged separately, not complexed, and asserted prescription due to delay in filing information.
Legal Framework on Reckless Imprudence and Penalties (RPC Article 365)
- Reckless imprudence causing acts which if intentional would be grave felony imposes penalty ranging from arresto mayor in its maximum to prision correccional in medium period.
- If acts would be less grave felony if intentional, penalty is arresto mayor in minimum and medium periods.
- If acts would be light felony if intentional, penalty is arresto menor in maximum period.
- Where damage to property only results, fine from value of the damage to thrice that value; minimum of ₱25.
- Courts exercise sound discretion without strict adherence to penalty gradation rules when imposing penalty under Article 365.
Supreme Court’s Ruling on the Proper Penalty
- The penalty of six months arresto mayor imposed was incorrect.
- The penalty for reckless imprudence resulting in slight physical injuries, a light felony punishable by arresto menor in its maximum period (21 to 30 days), is inapplicable here fully because of Article 365’s provisions.
- Due to the exception clause in Article 365, which mandates imposition of penalty next lower in degree when possible, the p