- Petitioner
- Isabelita Reodica
- Respondent
- Court of Appeals
- Citation
- G.R. No. 125066
- Court
- Supreme Court
- Decided
- July 8, 1998
Proper penalty for reckless imprudence resulting in slight physical injuries and property damage; jurisdiction and prescription of quasi-offenses;…
Summary
This criminal case involved Isabelita Reodica's conviction for reckless imprudence resulting in property damage and slight physical injuries from a 1987 vehicular collision. The RTC sentenced her to 6 months imprisonment and P13,542.00 damages, which the Court of Appeals affirmed. The Supreme Court reversed, finding multiple errors: the proper penalty for reckless imprudence causing slight physical injuries should be mere public censure under Article 365 of the Revised Penal Code, not imprisonment; the two quasi-offenses should not be treated as a complex crime since one constituted a light felony; and the RTC lacked jurisdiction as both offenses fell within the exclusive jurisdiction of lower courts under BP 129. The Court dismissed the case entirely for lack of jurisdiction, establishing important precedents on criminal negligence penalties, complex crime rules, and court jurisdiction over quasi-offenses.
Focus of dispute
Proper penalty for reckless imprudence resulting in slight physical injuries and property damage; jurisdiction and prescription of quasi-offenses; applicability of complex crime rules
Legal facts
On October 17, 1987, petitioner Isabelita Reodica was driving a van along Doña Soledad Avenue, Better Living Subdivision, Parañaque, Metro Manila when her vehicle collided with complainant Norberto Bonsol's Toyota Corolla due to alleged recklessness. The collision resulted in slight physical injuries to Bonsol requiring medical attention for less than 9 days and property damage amounting to P8,542.00. Three days after the incident, Bonsol filed an Affidavit of Complaint with the Fiscal's Office. An information was filed on January 13, 1988, charging petitioner with 'Reckless Imprudence Resulting in Damage to Property with Slight Physical Injury' before the RTC of Makati.
Judgement and reasoning
Court of Appeals (CA): Affirmed the RTC decision after reviewing petitioner's assigned errors. Denied petitioner's motion for reconsideration and supplemental motion for reconsideration for lack of merit. Upheld the trial court's conviction and penalty despite petitioner's arguments regarding improper penalty, jurisdiction, and prescription.
Regional Trial Court (RTC) of Makati: Convicted petitioner of quasi offense of reckless imprudence resulting in damage to property with slight physical injuries. Sentenced her to 6 months imprisonment (arresto mayor) and ordered payment of P13,542.00 (P8,542.00 car repairs + P5,000.00 medical expenses). Court justified imprisonment penalty citing that slight physical injuries through reckless imprudence is punished with arresto mayor in its maximum period, relying on People v. Aguilar case.
Supreme Court (SC): GRANTED the petition and SET ASIDE the CA decision. Dismissed Criminal Case No. 33919 for lack of jurisdiction. Court held: (1) Proper penalty for reckless imprudence resulting in slight physical injuries is public censure, not arresto menor or arresto mayor; (2) The two quasi-offenses (property damage and physical injuries) should not be complexed as one is a light felony; (3) RTC lacked jurisdiction as both offenses fell under MeTC/MTC jurisdiction; (4) Prescription was tolled by filing of complaint with fiscal's office; (5) Duplicitous information defect was waived by failure to object before trial.