Castillo v. Donato
REITERATIONFacts
The Antecedents: On January 25, 1978, Teodorico Castillo, while driving a Philippine National Railways bus, recklessly bumped a jeepney, resulting in the death of the jeepney driver and a passenger, and the total destruction of the jeepney. Procedural History: Castillo was charged with and convicted of double homicide and damage to property through reckless imprudence. He was sentenced to two indeterminate penalties, each with a minimum of two years and four months of prision correccional and a maximum of four years, nine months and ten days of prision correccional, and ordered to pay a fine of P25,000.00 for the damaged jeepney. The Appellate Court affirmed this judgment. Castillo's application for probation was denied due to the total imprisonment penalty exceeding six years. The Petition: Castillo filed a petition for certiorari and prohibition, contending that only one penalty for the two deaths should have been imposed.
Issue(s)
Whether the imposition of two indeterminate penalties for double homicide and damage to property through reckless imprudence arising from a single act is correct. Whether a final and executory judgment imposing an excessive penalty can be modified by the courts.
Ruling
The petition is dismissed. The Court noted that only one indeterminate penalty should have been imposed for the complex crime. However, since the decision had become final and executory, the courts could not modify the excessive penalty, and the remedy lay with the Chief Executive. The attention of the Chief Executive, through the Minister of Justice, was respectfully invited to the excessive penalty imposed.
Ratio Decidendi
On the imposition of two indeterminate penalties for a complex crime: The Court held that the petitioner committed the complex crime of double homicide and damage to property through reckless imprudence by means of his single act of bumping the jeep. Therefore, only one indeterminate penalty should have been imposed, citing People vs. Lara, People vs. Pacson, and People vs. Biador. The imposition of the imprisonment penalty and the fine is justified. On the modification of a final and executory judgment: The Court ruled that although the penalty imposed was excessive, the decision had become final and executory. Consequently, the courts could no longer change the penalty. The remedy for such a situation lies with the Chief Executive, not with the courts, citing Pomeroy vs. Director of Prisons.
Main Doctrine
A single act causing multiple deaths and damage to property constitutes a complex crime, and only one indeterminate penalty should be imposed. However, a final and executory judgment with an excessive penalty cannot be modified by the courts, and the remedy lies with the Chief Executive.