People v. Dayap
REITERATIONFacts
1. The Antecedents: The case originated from an Information filed on December 29, 2004, charging petitioner Jeffrey Reso Dayap with Reckless Imprudence resulting in Homicide, Less Serious Physical Injuries, and Damage to Property. The charge stemmed from an incident on December 28, 2004, where Dayap allegedly drove a 10-wheeler cargo truck in a reckless and imprudent manner, colliding with a Colt Galant automobile. This collision resulted in the instantaneous death of the driver of the automobile, Lou Gene R. Sendiong, less serious physical injuries to two passengers, Dexie Duran and Elvie Sy, and extensive damage to the automobile. 2. Procedural History: Petitioner pleaded not guilty to the charge before the Municipal Trial Court (MTC) of Sibulan, Negros Oriental. After the prosecution rested its case, the MTC granted petitioner's demurrer to evidence, acquitting him due to insufficiency of evidence. The MTC found that the prosecution failed to prove the crime and the petitioner's culpability, and further suggested that the swerving of the Colt Galant into the truck's lane was the proximate cause of the accident. Respondents filed a petition for certiorari with the Regional Trial Court (RTC), which affirmed the acquittal but remanded the case for further proceedings on the civil aspect. The respondents then filed a petition for review with the Court of Appeals (CA), which reversed the lower courts' decisions, ruling that the case fell under the jurisdiction of the RTC and remanding it for proper disposition. The CA later denied the petitioner's motion for reconsideration. 3. The Petition: Petitioner seeks review on certiorari of the CA's decision and resolution. He argues that the MTC had jurisdiction over the criminal case due to Republic Act No. 7691, which expanded the jurisdiction of first-level courts to include offenses punishable by imprisonment not exceeding six years and offenses involving damage to property through criminal negligence. Petitioner contends that the CA erred in ruling that jurisdiction pertained to the RTC, especially since the attempt to amend the information to include abandonment was withdrawn and approved by the MTC. Furthermore, petitioner asserts that his acquittal on the ground of insufficiency of evidence, particularly the finding that the act or omission did not exist and that he did not commit the imputed acts, extinguished his civil liability, rendering the remand for further proceedings on the civil aspect unnecessary.
Issue(s)
Whether the Court of Appeals erred in ruling that jurisdiction over the offense charged pertained to the Regional Trial Court (RTC). Whether the Court of Appeals erred in ordering the remand of the case for further proceedings on the civil liability.
Ruling
The petition is GRANTED. The Court of Appeals’ Decision dated 17 August 2006 and Resolution dated 25 April 2007 in CA-G.R. SP. No. 01179 are REVERSED and SET ASIDE. The Order dated 16 May 2005 of the Municipal Trial Court of Sibulan, Negros Oriental in Criminal Case No. 3016-04 granting the Demurrer to Evidence and acquitting petitioner Jeffrey Reso Dayap of the offense charged therein is REINSTATED and AFFIRMED.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the Court of Appeals erred in ruling that jurisdiction pertained to the RTC. The original Information charged petitioner with reckless imprudence resulting in homicide, less serious physical injuries, and damage to property. This offense, punishable by prision correccional in its medium and maximum periods, falls within the exclusive original jurisdiction of the Municipal Trial Court (MTC) pursuant to Section 32(2) of Batas Pambansa Bilang 129, as amended by Republic Act No. 7691. RA 7691 expanded the jurisdiction of first-level courts to include offenses punishable by imprisonment not exceeding six years, irrespective of the amount of fine, and specifically granted them exclusive original jurisdiction over offenses involving damage to property through criminal negligence. The attempt to amend the Information to include abandonment was withdrawn and approved by the MTC, thus the case proceeded based on the original Information, which did not confer jurisdiction upon the RTC. On the issue of civil liability: The Court disagreed with both the CA and the RTC regarding the remand of the case for further proceedings on the civil aspect. The acquittal of the accused does not automatically extinguish civil liability, unless the acquittal is based on a finding that the act or omission from which civil liability may arise did not exist, or that the accused did not commit the imputed acts. In this case, the MTC's Order granting the demurrer to evidence explicitly stated that it could not find any evidence proving that a crime had been committed or that the accused was responsible for it. The MTC further found that the proximate cause of the accident was the swerving of the Colt Galant, not the petitioner's alleged reckless driving. These findings clearly indicate that the acquittal was based on the non-existence of the act or omission imputed to the petitioner, thereby extinguishing his civil liability. Consequently, there was no need to remand the case for further proceedings on the civil aspect.
Main Doctrine
An acquittal based on a demurrer to evidence, where the court finds that the act or omission from which civil liability may arise did not exist or that the accused did not commit the imputed acts, extinguishes civil liability. Such acquittal, being a dismissal on the merits, cannot be appealed, but may be reviewed via certiorari under Rule 65 for grave abuse of discretion.