People v. Morales
ABANDONMENTFacts
1. The Antecedents: On May 14, 2013, petitioner Francis O. Morales was driving a Mitsubishi Delica Van along Sto. Rosario Street corner San Jose Street, Angeles City. While attempting to overtake another vehicle, he allegedly drove in a careless, reckless, and imprudent manner, violating traffic laws. This resulted in his van colliding with an Isuzu Jitney driven by Rico M. Mendoza. The collision caused serious physical injuries to Rico, slight physical injuries to passengers Leilani Mendoza and Myrna Cunanan, and damage to the Isuzu Jitney estimated at P350,000.00. 2. Procedural History: The petitioner was charged with Reckless Imprudence Resulting in Damage to Property and Multiple Physical Injuries. The Municipal Trial Court in Cities (MTCC) convicted him and imposed penalties and indemnifications. The Regional Trial Court (RTC) affirmed this decision. The Court of Appeals (CA) affirmed the conviction but modified the penalty and damages. The petitioner's motion for reconsideration was denied. Subsequently, the petitioner filed a petition for review on certiorari with the Supreme Court. The Supreme Court initially denied this petition in a Resolution dated September 21, 2020. The present case is a Motion for Reconsideration of that Resolution. 3. The Petition: The petitioner, through a Motion for Reconsideration, argues that the CA erred in giving full faith to the Traffic Accident Report (TAR) and insists that the collision occurred within his lane, not the jeepney's. He contends that the physical evidence suggests the jeepney steered into his van and that the driver, Rico Mendoza, had the last clear chance to avoid the accident. He also argues that the award of temperate damages is baseless due to a lack of proven negligence and that the CA erred in applying Republic Act No. 10951, which increased the penalty from the lower courts' imposition. The petitioner seeks to overturn his conviction and the penalties imposed.
Issue(s)
Whether the Court of Appeals erred in affirming the conviction of the petitioner for reckless imprudence resulting in multiple physical injuries and damage to property. Whether Article 48 of the Revised Penal Code applies to quasi-offenses under Article 365 of the Revised Penal Code. Whether the penalty imposed by the Court of Appeals is correct, considering the nature of the injuries and the applicability of R.A. No. 10951.
Ruling
The Supreme Court denied the Motion for Reconsideration but modified the penalty imposed. It found the petitioner guilty beyond reasonable doubt of reckless imprudence resulting in multiple slight physical injuries and damage to property. The petitioner was sentenced to suffer the penalty of public censure for each of the resulting slight physical injuries committed against Rico Mendoza, Leilani Mendoza, and Myrna Cunanan. He was also ordered to pay a fine of P150,000.00 as penalty for the damage to property, temperate damages to the Mendozas and Myrna Cunanan, and temperate damages to Noel G. Garcia. All monetary awards are subject to 6% interest per annum from finality.
Ratio Decidendi
On the conviction for reckless imprudence: The Court affirmed the conviction, holding that the prosecution established the elements of reckless imprudence. Petitioner voluntarily, without malice, and with inexcusable lack of precaution, overtook a vehicle without ensuring the road was clear, violating Section 41 of R.A. No. 4136. The point of impact being in the jeepney's lane indicated petitioner's encroachment. Article 2185 of the New Civil Code presumes negligence when violating a traffic regulation, a presumption petitioner failed to rebut. The findings of fact by the lower courts, affirmed by the CA, were binding on the Supreme Court. On the applicability of Article 48 of the RPC to quasi-offenses: The Court definitively ruled that Article 48 of the RPC, which deals with complex crimes, does not apply to quasi-offenses under Article 365. The Court reiterated its pronouncements in Ivler v. Hon. Judge Modesto-San Pedro, emphasizing that reckless imprudence is a distinct crime, not a mere modality of committing a crime. Therefore, each consequence of a single imprudent act must be penalized separately. The Court explicitly abandoned the ruling in People v. De los Santos which allowed the application of Article 48 to crimes through negligence. On the penalty and damages: The Court clarified that the injuries sustained by Rico, Leilani, and Myrna were slight physical injuries, which constitute a light felony. Reckless imprudence resulting in a light felony is punishable by arresto menor in its maximum period. However, due to the provision in Article 365 that when the penalty for the intentional offense is equal to or lower than that for reckless imprudence, the penalty next lower in degree shall be imposed, the penalty for reckless imprudence resulting in slight physical injuries is public censure. For the damage to property, the Court affirmed the CA's award of temperate damages of P150,000.00 to Noel G. Garcia, as actual damages could not be proven with certainty. The Court also affirmed the award of temperate damages to the Mendozas and Myrna Cunanan for lost income, as their earnings could not be substantiated. The penalty for damage to property is a fine ranging from the value of the damage to three times such value, but not less than P5,000.00, and the Court imposed a fine of P150,000.00.
Main Doctrine
The Supreme Court En Banc clarified that Article 48 of the Revised Penal Code (RPC) does not apply to quasi-offenses under Article 365 of the RPC, as reckless imprudence is a distinct crime and not merely a way of committing a crime. Consequently, each consequence of a single imprudent act must be penalized separately, and the doctrine in Ivler v. Hon. Judge Modesto-San Pedro is affirmed, while People v. De los Santos is abandoned.