People v. Veneracion
REITERATIONFacts
The Antecedents: On December 10, 1989, petitioner Robert Veneracion was driving a trailer-truck along E. delos Santos Avenue (EDSA) intending to make a left turn on B. Serrano Street. Dr. Conrado Triguero was driving his Toyota Corolla and was at a full stop at the intersection of EDSA and B. Serrano Street, also negotiating a left turn. The trailer-truck bumped the left center portion of Dr. Triguero's car, causing damage amounting to ₱27,080.00. Procedural History: The Regional Trial Court (RTC) found petitioner guilty beyond reasonable doubt of Damage to Property thru Reckless Imprudence under Article 365 of the Revised Penal Code and sentenced him to pay a fine of ₱24,900.00. The RTC noted that Dr. Triguero had filed a separate civil action. The Court of Appeals (CA) affirmed the RTC Decision in toto. The Petition: Petitioner seeks a review of the CA Decision, contending that the CA erred in presuming his negligence, relying on conjecture, and contravening the findings of fact of the trial court. He also argued that the doubt should have been resolved in his favor and that he should not be liable for the fine.
Issue(s)
Whether the Court of Appeals erred in presuming negligence on the part of the petitioner and contravening the findings of fact of the trial court. Whether the Court of Appeals erred in not resolving the doubt in favor of the petitioner. Whether the Court of Appeals erred in not declaring that the petitioner is not liable to pay the fine of ₱24,900.00.
Ruling
The petition is denied, and the Decision and Resolution of the Court of Appeals in CA-G.R. No. 14512 are affirmed.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in presuming negligence and contravening the findings of fact of the trial court: The Court found no basis for the petitioner's argument that the CA contravened the RTC's findings. The portion of the RTC Decision cited by the petitioner merely narrated the accused's version of the incident, not its ultimate finding. The RTC ultimately found the prosecution's version credible, supported by evidence. The RTC's detailed findings, corroborated by photographic evidence (Exhibits "E" to "M"), indicated that Dr. Triguero's car was ahead of the trailer-truck and was already making a left turn when the trailer-truck bumped its left side. The CA fully agreed with these findings, noting that the record was replete with evidence supporting the prosecution's version. The CA also observed scratch marks on the car consistent with the trailer-truck bumping it from behind, further substantiating the RTC's conclusion. On the issue of whether the Court of Appeals erred in not resolving the doubt in favor of the petitioner: The Court held that the RTC and CA were in agreement regarding the facts and circumstances of the incident. The rule is that when the findings of fact of the lower courts are consistent and supported by evidence, they will not be disturbed on appeal. The petitioner's main defense was that Dr. Triguero was at fault, which was contradicted by the evidence and the concurrent findings of both the RTC and CA. Therefore, there was no doubt to be resolved in favor of the petitioner. On the issue of whether the Court of Appeals erred in not declaring that the petitioner is not liable to pay the fine of ₱24,900.00: The petitioner's conviction for Damage to Property thru Reckless Imprudence under Article 365 of the Revised Penal Code was affirmed. The CA found that the petitioner operated the trailer-truck imprudently by failing to observe the necessary precaution to avoid damage. The prosecution proved that the car was ahead of the trailer truck prior to the collision, making it incumbent upon the petitioner to reduce speed or brake to allow the car to safely negotiate its turn. His failure to do so constituted reckless imprudence. The fine imposed by the RTC was affirmed by the CA.
Main Doctrine
The findings of fact of the trial court and the Court of Appeals, when in agreement, are generally binding and will not be disturbed on appeal, absent any overlooked facts of substance or other compelling reason.