- Petitioner
- Marcelino M. Dela Cruz
- Respondent
- People
- Citation
- G.R. No. 219038
- Court
- Supreme Court
- Decided
- July 6, 2021
Criminal liability for reckless imprudence resulting in homicide and damage to property in a vehicular accident
Summary
Bus driver Marcelino Dela Cruz was convicted of reckless imprudence resulting in homicide and damage to property after his bus rear-ended a car on NLEX, killing passenger Azucena Miranda and injuring driver Claudio Miranda. The Supreme Court affirmed his conviction, finding that his negligent overtaking maneuver without proper precaution was the proximate cause of the accident. The Court emphasized that public utility drivers have heightened responsibility for safety and that contributory negligence cannot exonerate an accused whose own negligence is established. The penalty was modified to 4 months and 1 day to 4 years and 2 months imprisonment, with civil damages including P50,000 civil indemnity, P83,099 actual damages, and P50,000 moral damages to the victim's heirs, plus damages to the injured driver and vehicle owner.
Focus of dispute
Criminal liability for reckless imprudence resulting in homicide and damage to property in a vehicular accident
Legal facts
On May 19, 2006, at about 4:00 PM, accused Marcelino M. Dela Cruz was driving a Tata Paul Transit Bus with Plate No. RBS 431 along the North Luzon Expressway in Balagtas, Bulacan. He collided with a Mitsubishi Lancer driven by Claudio Miranda with passenger Azucena Miranda. The collision occurred when Marcelino attempted to overtake another vehicle by shifting to the third lane where Claudio's car was traveling. The impact caused Claudio's car to spin and hit the concrete barrier. Azucena Miranda died instantly, Claudio suffered physical injuries, and the vehicles sustained damage worth P160,000.00. Investigation revealed skid marks from the bus indicating high speed and sudden braking.
Judgement and reasoning
Court of Appeals (CA): Affirmed the conviction but modified the imprisonment sentence to 4 months arresto mayor maximum as minimum period to 2 years, 10 months and 20 days prision correccional medium as maximum period. Agreed that the proximate cause of collision was Marcelino's negligence in hastily overtaking another vehicle in an imprudent and reckless manner.
Municipal Trial Court (MTC): Found Marcelino guilty beyond reasonable doubt of reckless imprudence resulting in homicide and damage to property. Sentenced him to 4 months arresto mayor as minimum to 4 years, 2 months prision correccional as maximum. Ordered payment of actual damages P83,099.00 and moral damages P50,000.00 to heirs of Azucena Miranda, P1,966.00 actual damages to Claudio Miranda for injuries, and P160,000.00 for car damage. Held that Marcelino was negligent in overtaking with a defective speedometer and failed to exercise due prudence.
Regional Trial Court (RTC): Affirmed the MTC decision finding no reversible error. Held that as the driver of the overtaking bus, Marcelino failed to take necessary precautions to ensure safety of all vehicles concerned at the time of incident.
Supreme Court (SC): Denied the petition and affirmed with modification. Modified the penalty to 4 months and 1 day arresto mayor as minimum and 4 years and 2 months prision correccional as maximum. Added P50,000.00 civil indemnity to the heirs of Azucena Miranda. Held that Marcelino failed to meet his obligation as a public utility driver to exercise due care, and that his elevated driving position should have allowed him to see Claudio's car before overtaking. Ruled that contributory negligence cannot exonerate an accused whose own negligence has been clearly established.