People v. Aguilar
REITERATIONFacts
The Antecedents: On June 24, 1955, an information was filed charging Benjamin Aguilar y Perez and Jose Oliveros y Olat with multiple slight physical injuries through reckless imprudence. The information alleged that while driving their respective passenger jeepneys, they operated their vehicles in a careless, reckless, and imprudent manner, at a speed greater than reasonable and proper, and without taking necessary precautions, causing their vehicles to collide. As a result, five passengers sustained physical injuries requiring medical attendance for more than one but not more than nine days, and incapacitating them from their customary labor for the same period. Procedural History: The defendants filed motions to quash the information, arguing that reckless imprudence is punishable only if the acts complained of constitute a grave or less grave felony. The Municipal Court granted the motions. The City Fiscal appealed, and the Court of First Instance of Manila sustained the order, dismissing the case. The People of the Philippines appealed this dismissal. The Petition: The People contended that the trial court erred in dismissing the case on the ground that the facts alleged in the information did not constitute an offense and that the law did not provide a penalty thereof.
Issue(s)
Whether an information charging "multiple slight physical injuries thru reckless imprudence" constituted a punishable offense under Article 365 of the Revised Penal Code, prior to the enactment of Republic Act No. 1790.
Ruling
The Supreme Court set aside the order appealed from and directed that the case be remanded to the trial court for hearing on the merits. No costs were awarded.
Ratio Decidendi
On Whether an information charging "multiple slight physical injuries thru reckless imprudence" constituted a punishable offense under Article 365 of the Revised Penal Code, prior to the enactment of Republic Act No. 1790: The Supreme Court held that the trial court erred in sustaining the motion to quash and in dismissing the case. The Court acknowledged that Article 365 of the Revised Penal Code, prior to its amendment by Republic Act No. 1790 (promulgated on June 21, 1957), did not explicitly include an act of "reckless imprudence" that, if done intentionally, would have constituted a light felony, such as slight physical injuries. The Court noted that Article 365 punished acts by reckless negligence resulting in grave or less grave felonies, and acts by simple negligence resulting in grave, less grave, or light felonies. However, it applied the principle enunciated in People vs. Benigno Lingad, where it was held that an information, while designating the crime as "slight physical injuries thru reckless imprudence," but vaguely alleging that it was committed "in a careless, reckless, negligent and imprudent manner," could be inferred to cover either reckless or simple negligence. The Court reasoned that what is more or graver includes the less or lighter, meaning that a charge of reckless imprudence can encompass simple negligence. Therefore, it could still be shown during trial that the accused committed the act through simple negligence, which was punishable under Article 365 for light felonies. The determination of the precise kind and degree of negligence was deemed a matter of evidence to be substantiated during the trial, not a proper ground for quashing the information.
Main Doctrine
The Revised Penal Code, prior to its amendment by Republic Act No. 1790, did not penalize slight physical injuries committed through reckless imprudence. However, allegations in an information that merely describe the act as 'careless, reckless, negligent and imprudent manner' without specifying the degree of negligence may still be prosecuted, as the distinction between reckless and simple negligence may be a matter of evidence.