People v. Beltran
REITERATIONFacts
The Antecedents: The accused, Eleuterio Beltran y Angeles, was charged with jaywalking in violation of Rule IX, paragraph 2, of Municipal Ordinance No. 2646 (Traffic Code) of the City of Manila. The information alleged that he unlawfully jaywalked along the South approach of Jones Bridge by crossing the street outside of the pedestrian lane. Procedural History: The Municipal Court found the accused guilty and sentenced him to pay a fine of P15 and costs, with subsidiary imprisonment in case of insolvency. The accused appealed to the Court of First Instance (CFI) of Manila. After the prosecution rested its case, the CFI granted the defendant's motion to submit a motion to dismiss, with the understanding that if denied, the case would be submitted for decision on the question of law. On December 12, 1956, the CFI rendered judgment, holding that the act admitted by the accused constituted a violation of Rule IX, paragraph 2, in relation to the second part of paragraph 3 of Ordinance No. 2646, and imposed the same penalty. The defendant appealed to the Supreme Court. The Petition: The accused appealed the CFI's decision, arguing that his conviction was not sustainable.
Issue(s)
Whether the act of crossing Magallanes Street at a point not marked as a pedestrian lane constitutes a punishable violation of Rule IX, Ordinance No. 2646, given the specific street enumerations and sign-posting requirements contained therein.
Ruling
The judgment appealed from is reversed, and the appellant is acquitted, with costs de oficio.
Ratio Decidendi
On Issue 1: The Supreme Court held that the conviction cannot be sustained because the act did not violate the specific penal prohibitions of the ordinance. The Court analyzed Rule IX, noting that Paragraph 2 provides a general preference that pedestrians 'should' cross at right angles or regular crossings to insure safety, but it is Paragraph 3 that defines the unlawful acts and lists the specific streets where crossing is prohibited. Magallanes Street is not included in the list of streets (such as Escolta, Rosario, and Rizal Avenue) where crossing outside of marked safety lines is declared unlawful. Applying the principle of strict construction of penal laws, the Court found that the prohibition in Paragraph 3 does not extend to streets not named therein. Furthermore, the second part of Paragraph 3 expressly provides that 'until such safety zones have been properly marked and sign-posted... no prosecutions shall be instituted against any one for violation of the provisions of this paragraph.' Since the evidence established that there were no sign-posts in the vicinity where the accused crossed, the mandatory condition for prosecution was not met. Consequently, the crossing of Magallanes Street, which is otherwise allowed at right angles under the general guidelines of Paragraph 2, does not constitute a criminal offense under the circumstances.
Main Doctrine
A conviction for jaywalking under Municipal Ordinance No. 2646 cannot be sustained if the street in question is not among those enumerated in paragraph 3 of the ordinance, and the crossing, even if not at a designated pedestrian lane, is done at a right angle and not prohibited by specific provisions.