- Petitioner
- People
- Respondent
- Benigno Lingad y Vito
- Citation
- G.R. No. L-10952
- Court
- Supreme Court
- Decided
- May 30, 1958
Whether slight physical injuries committed through reckless imprudence is punishable under Philippine criminal law, specifically under Article 365 of…
Summary
This Supreme Court case clarified the scope of criminal liability under Article 365 of the Revised Penal Code regarding negligent acts causing physical injuries. Defendant Benigno Lingad was charged with slight physical injuries through reckless imprudence after a vehicular accident that injured Mayor Arsenio Lacson. The Court of First Instance dismissed the case, ruling that such acts are not punishable under Philippine law. However, the Supreme Court En Banc reversed this decision, holding that informations alleging reckless imprudence can encompass simple negligence, which is punishable under Article 365. The Court applied the principle that greater offenses include lesser ones, allowing prosecution to proceed based on evidence that may prove simple rather than reckless negligence. This decision established important precedent regarding the interpretation of criminal negligence provisions and the sufficiency of criminal informations in cases involving varying degrees of imprudence.
Focus of dispute
Whether slight physical injuries committed through reckless imprudence is punishable under Philippine criminal law, specifically under Article 365 of the Revised Penal Code
Legal facts
On October 28, 1954, in Manila, Benigno Lingad y Vito was driving a pick-up truck with plate No. T-518 (Cavite-'54) along Arroceros Street in a careless, reckless, negligent and imprudent manner at excessive speed. His vehicle struck and bumped against a stopped car No. PI-2578 (Manila) driven by Det. Mariano Joaquin. As a result of the violent impact, Mayor Arsenio Lacson, a passenger in the stopped car, sustained physical injuries requiring medical attendance for more than 1 but less than 10 days and preventing him from engaging in customary labor for the same period. Lingad was charged with slight physical injuries through reckless imprudence.
Judgement and reasoning
Court of First Instance: Granted defendant's motion to quash and dismissed the case, holding that the crime of slight physical injuries when committed through reckless imprudence is not punishable by law. The court relied on the Court of Appeals decision in People vs. Macario Ande y Marino, which held that the law does not declare as a crime acts committed through reckless imprudence which, if intentional, would amount only to a light felony.
Municipal Court of Manila: Found Benigno Lingad y Vito guilty of slight physical injuries through reckless imprudence and sentenced him to pay a fine of P50 with subsidiary imprisonment in case of insolvency, and to pay the costs.
Supreme Court (En Banc): Reversed the Court of First Instance and set aside the dismissal order. The Supreme Court held that the trial court erred in sustaining the motion to quash. The Court reasoned that while Article 365 of the Revised Penal Code provides penalties only for acts committed through 'simple imprudence or negligence' that would constitute light felonies if done maliciously, the information's vague allegations of imprudence could encompass either reckless or simple negligence depending on evidence presented. Applying the principle that what is more or graver includes the less or lighter (similar to how serious physical injury includes slight injury), the Court determined that the case could proceed as it might be proven that defendant committed the act through simple negligence. The elements of both kinds of negligence are practically the same, differing only in degree, which can be substantiated by proper evidence. Case remanded to trial court for hearing on the merits.