People v. Paman
REITERATIONFacts
1. The Antecedents: On October 14, 2004, Ursicio Arambala was riding his motorcycle when a multicab driven by S/Sgt. Cornelio Paman collided with him. Arambala was thrown from his motorcycle, hitting his head on the pavement, and sustained a cerebral hematoma requiring hospitalization and subsequent readmission due to complications. The incident occurred at the intersection of Roxas and Broca Streets in Pagadian City. 2. Procedural History: An Information for reckless imprudence resulting in serious physical injuries was filed against Paman. The Municipal Trial in Cities (MTCC) convicted Paman, sentencing him to one month and one day to four months of arresto mayor. However, the Regional Trial Court (RTC) reversed this decision, acquitting Paman, finding Arambala to be the cause of the collision. The People of the Philippines, through the Solicitor General, filed a petition for certiorari with the Court of Appeals (CA), arguing grave abuse of discretion by the RTC. The CA granted the petition, setting aside the RTC's acquittal and reinstating Paman's conviction with a modified sentence of one month and one day of arresto mayor to two years and four months of prision correccional. 3. The Petition: S/Sgt. Cornelio Paman filed this petition for review on certiorari under Rule 45 of the Rules of Court, seeking to annul the CA's decision and resolution. Paman argues that the RTC did not commit grave abuse of discretion in acquitting him and that certiorari was not the proper remedy to assail the acquittal. He maintains that the prosecution's evidence was insufficient to prove his guilt beyond reasonable doubt and reiterates that Arambala was at fault for the collision.
Issue(s)
Whether a petition for certiorari under Rule 65 is the proper remedy to assail an acquittal tainted with grave abuse of discretion. Whether the RTC committed grave abuse of discretion in acquitting Paman. Whether Paman is guilty beyond reasonable doubt of reckless imprudence resulting in serious physical injuries.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed with modification, sentencing S/Sgt. Cornelio Paman to suffer the penalty of imprisonment of two (2) months and one (1) day of arresto mayor.
Ratio Decidendi
On the propriety of certiorari to assail acquittal: The Court reiterated that while a judgment of acquittal is generally final and unappealable, this rule is not absolute. A petition for certiorari under Rule 65 is the proper remedy to question an acquittal when the trial court commits grave abuse of discretion amounting to a lack or excess of jurisdiction. The OSG successfully demonstrated that the RTC gravely abused its authority by disregarding the evidence on record and ruling that no liability could be attached to Paman solely based on its finding that Arambala caused the collision. This extraordinary remedy is available to correct egregious errors that effectively deny due process or jurisdiction. On the RTC's grave abuse of discretion: The RTC committed grave abuse of discretion by completely disregarding the evidence presented by the prosecution. The evidence indubitably showed that Paman was driving on the wrong side of the road when his multicab suddenly crossed Arambala's path. The position of the multicab after the incident further supported the conclusion that Paman was on the wrong lane. The RTC's finding that Arambala was at fault was not supported by the evidence, which clearly indicated Paman's negligence as the proximate cause of the collision. On Paman's guilt for reckless imprudence: Paman's act of driving on the wrong side of the road to overtake Arambala's motorcycle, thereby suddenly crossing the latter's path, constituted sheer negligence. This action violated Section 41(a) of Republic Act No. 4136, the Land Transportation and Traffic Code. Under Article 2185 of the Civil Code, a driver violating a traffic regulation is presumed negligent unless proven otherwise. Paman failed to overcome this presumption. The proximate cause of the incident was Paman's reckless act of using the wrong lane, which led to the collision and Arambala's injuries. The MTCC correctly found Paman guilty based on the evidence presented.
Main Doctrine
A petition for certiorari under Rule 65 is the proper remedy to assail an acquittal tainted with grave abuse of discretion, as the rule on the finality of acquittal is not absolute and does not preclude review when the trial court disregards evidence and acts without jurisdiction. Driving on the wrong side of the road in violation of traffic regulations creates a presumption of negligence, which must be overcome by proof to the contrary.