Title
Veneracion vs. People
Case
G.R. No. 137447
Decision Date
Jan 31, 2005
Driver of trailer-truck collided with a car, causing P24,900 damage; courts found driver guilty of reckless imprudence, fined accordingly.
reckless imprudence
damage to property
car accident

Case Summary (G.R. No. 137447)

Factual Background

Robert Veneracion was the driver and person in charge of a tractor-trailer bearing Plate No. CVC-137, registered in the name of Rock Component Phil. Inc. The trailer-truck had exited the North Expressway and was traveling west along E. delos Santos Avenue (EDSA) toward Kalookan City with the intention to make a left turn on B. Serrano Street. Further down the road, a two-door Toyota Corolla, model 1981, bearing Plate No. NME-429 and owned and driven by Dr. Conrado Triguero, came to a full stop at the center of the intersection of EDSA and B. Serrano Street and was negotiating a left turn. As the car turned, the right front fender of the trailer-truck struck the left center portion of the car toward the driver’s seat. The crash produced damage to the car; the prosecuting records included an Official Receipt reflecting payment of P24,900.00 to Accurate Motor Works for repairs.

Trial Court Proceedings

The Information charged Robert Veneracion with reckless imprudence resulting in damage to property for operating the tractor-trailer in a reckless, negligent, and imprudent manner, causing damage alleged at P27,080.00. At trial the prosecution introduced documentary evidence including the car registration (Exh. A), an official receipt (Exh. T), and photographs of the scene (Exhs. E to M). Dr. Conrado Triguero testified and exhibited his driver’s license (Exh. D). The accused did not produce his driver’s license and did not introduce his purported Exh. 1. The Regional Trial Court evaluated the testimonial and documentary evidence, credited the prosecution’s version, and found the accused guilty beyond reasonable doubt of the offense charged under Article 365, third paragraph, of the Revised Penal Code. The trial court sentenced the accused to pay a fine of P24,900.00 and declined to provide indemnity because a separate civil action by the offended party against the accused and the employer, Rock Component Philippines, Inc., was pending.

Court of Appeals Proceedings

The Court of Appeals reviewed the record and affirmed the trial court Decision in toto. The CA found the record “teeming with evidence supporting the version of the prosecution.” The appellate court emphasized the photographs which showed the car to be ahead of the trailer-truck prior to impact and exhibited scratch marks running from the back of the car toward its center, a circumstance from which it concluded that the trailer-truck had bumped the car from behind. The CA applied Article 365 and held that, because the car was clearly ahead, it was incumbent upon the appellant to reduce speed or apply brakes to allow the car to complete the left turn safely. The CA also addressed appellant’s contention regarding comparative driving experience, stating that lack of experience may be relevant but does not, by itself, absolve one of imprudence where other evidence established negligent operation.

Issues Presented

The petition to the Supreme Court advanced three principal assignments of error as stated by the petitioner: (I) that the respondent court erred in presuming negligence on the part of the petitioner and relying on conjecture, surmise, and speculation thereby contravening the findings of fact of the trial court; (II) that the respondent court erred in not resolving the doubt in favor of the petitioner; and (III) that the respondent court erred in not declaring that petitioner was not liable to pay the fine of P24,900.00.

Petitioner’s Contentions

Robert Veneracion contended that the Court of Appeals contravened the factual findings of the Regional Trial Court and that the CA’s version of events conflicted with the trial court’s narration of the accused’s version of the incident. The petitioner urged that the doubt should have been resolved in his favor and that he should not have been held liable for payment of the P24,900.00 fine imposed by the trial court.

Ruling of the Supreme Court

The Supreme Court denied the petition for review on certiorari and affirmed the Decision and Resolution of the Court of Appeals in CA-G.R. No. 14512. The Court held that the petitioner essentially sought a retrial on facts and that there was no basis to disturb the concurrent factual findings of the trial court and the appellate court. The Court noted that there were no overlooked facts of substance nor compelling reason warranting modification of the factual conclusions reached below. The Court’s Judgment was concurred in by Davide Jr., C.J., Quisumbing, Ynares-Santiago and Carpio, JJ.

Legal Basis and Reasoning

The Supreme Court reviewed the evidentiary record that supported the lower courts’ conclusions. The trial court had weighed testimonial evidence and documentary exhibits, including photographs (Exhs. E to M) that depicted the relative positions of the vehicles at the time of impact, and an official receipt (Exh. T) substantiating the amount actually paid for repairs. The trial court noted that the accused did not produce his driver’s license and did not formally introduce his claimed documentary exhibit. The Court of Appeals found the photographs decisive in showing the car ahead of the trailer-truck and identified scratch marks consistent with a contact from the tru

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