Isabelita Reodica v. Court of Appeals and People of the Philippines
REITERATIONFacts
1. The Antecedents: On October 17, 1987, Isabelita Reodica was driving a van when it collided with the car of Norberto Bonsol along Doña Soledad Avenue, Better Living Subdivision, Parañaque, Metro Manila. The collision resulted in physical injuries to Bonsol and damage to his vehicle amounting to P8,542.00. Three days later, Bonsol filed a complaint against Reodica. 2. Procedural History: An information was filed on January 13, 1988, before the Regional Trial Court (RTC) of Makati, charging Reodica with Reckless Imprudence Resulting in Damage to Property with Slight Physical Injury. The RTC convicted Reodica on January 31, 1991, sentencing her to six months of arresto mayor and to pay damages. Reodica appealed to the Court of Appeals (CA), which affirmed the RTC decision on January 31, 1996. A motion for reconsideration was denied by the CA on May 24, 1996. 3. The Petition: Reodica filed a petition for review on certiorari under Rule 45 of the Rules of Court. She argued that the penalty imposed was excessive due to a misinterpretation of the case People v. Aguilar, that the offenses should not have been treated as a complex crime, and that the RTC lacked jurisdiction and the offenses had prescribed. The Supreme Court granted the petition, finding that the RTC lacked jurisdiction over the case.
Issue(s)
Whether the penalty imposed on petitioner is correct. Whether the quasi offenses of reckless imprudence resulting in damage to property and reckless imprudence resulting in slight physical injuries are light felonies. Whether the rule on complex crimes under Article 48 of the Revised Penal Code applies to the quasi offenses in question. Whether the duplicity of the information may be questioned for the first time on appeal. Whether the Regional Trial Court had jurisdiction over the offenses in question. Whether the quasi offenses in question have already prescribed.
Ruling
The petition is GRANTED. The decision of the Court of Appeals is SET ASIDE, and Criminal Case No. 33919 is DISMISSED for lack of jurisdiction on the part of the Regional Trial Court.
Ratio Decidendi
On Whether the penalty imposed on petitioner is correct: The Court agreed that the penalty of six months of arresto mayor was incorrect. For reckless imprudence resulting in slight physical injuries, a light felony, the penalty is arresto menor in its maximum period. However, due to the exception in Article 365, the proper penalty is public censure, being the next lower penalty in degree. For reckless imprudence resulting in damage to property, the penalty is arresto mayor in its minimum and medium periods, as the third paragraph of Article 365 does not apply when the imprudence results in both damage to property and physical injuries. On Whether the quasi offenses are light felonies: Reckless imprudence resulting in slight physical injuries is a light felony because its penalty is public censure, which is a light penalty. However, reckless imprudence resulting in damage to property, penalized with arresto mayor in its minimum and medium periods, is a less grave felony, not a light felony. On Whether the rule on complex crimes applies: The rule on complex crimes under Article 48 of the Revised Penal Code does not apply when one of the resulting offenses is a light felony. Since reckless imprudence resulting in slight physical injuries is a light felony, it cannot be complexed with the less grave felony of reckless imprudence resulting in damage to property. These should be treated as separate offenses. On Whether the duplicity of the information may be questioned for the first time on appeal: While the information was duplicitous by charging two separate offenses, the petitioner waived this defect by failing to raise it in a motion to quash before pleading. Under Section 3, Rule 120 of the Rules of Court, the court may convict the accused of as many offenses as are charged and proved if this defect is not objected to before trial. On Whether the Regional Trial Court had jurisdiction: At the time of the filing of the information, offenses punishable by imprisonment not exceeding four years and two months, or a fine not exceeding P4,000.00, or both, fell under the exclusive original jurisdiction of the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts. Reckless imprudence resulting in slight physical injuries, punishable by public censure, and reckless imprudence resulting in damage to property, punishable by arresto mayor in its minimum and medium periods (1 month and 1 day to 4 months), both fell within the jurisdiction of these lower courts. Therefore, the RTC of Makati lacked jurisdiction over the case. On Whether the quasi offenses have already prescribed: Pursuant to Article 91 of the Revised Penal Code, the prescriptive period is interrupted by the filing of the complaint or information. The filing of the complaint with the fiscal's office three days after the incident tolled the prescriptive period for both offenses. The ruling in Zaldivia v. Reyes is not applicable as it involved a municipal ordinance and Act No. 3326, whereas this case involves offenses under the Revised Penal Code.
Main Doctrine
The Regional Trial Court lacks jurisdiction over offenses punishable by public censure, such as reckless imprudence resulting in slight physical injuries, as these fall within the jurisdiction of lower courts. Furthermore, the filing of a complaint with the fiscal's office interrupts the prescriptive period for offenses covered by the Revised Penal Code.