- Petitioner
- People
- Respondent
- Benjamin Aguilar y Perez
- Citation
- G.R. No. L-11302
- Court
- Supreme Court
- Decided
- October 28, 1960
Whether reckless imprudence causing slight physical injuries is punishable under Article 365 of the Revised Penal Code
Summary
Two drivers were charged with multiple slight physical injuries through reckless imprudence after their vehicles collided, injuring five passengers. Lower courts dismissed the case via motions to quash, ruling that Article 365 of the Revised Penal Code did not punish reckless imprudence causing light felonies. The Supreme Court reversed, holding that the information's broad allegations could encompass simple negligence, which is punishable for light felonies under Article 365. The Court applied the principle that graver charges include lesser ones, allowing prosecution to proceed under simple negligence theory. The case was remanded for trial on the merits, establishing important precedent on prosecuting vehicular accidents causing slight injuries.
Focus of dispute
Whether reckless imprudence causing slight physical injuries is punishable under Article 365 of the Revised Penal Code
Legal facts
On April 25, 1955, Benjamin Aguilar (jeepney driver) and Jose Oliveros (taxicab driver) collided at the corner of Requesens and Oroquieta streets in Manila due to careless, reckless and imprudent driving at excessive speed without proper precautions. The collision resulted in slight physical injuries to five jeepney passengers: Erlinda Saludes y Alfonso, Renato Saludes y Alfonso, Rosa Almario Amistoso, Leonisa Amistoso, and Avelino Miranda, requiring medical attendance for 1-9 days and incapacitating them from work for the same period.
Judgement and reasoning
Court of First Instance of Manila: Sustained the municipal court's order granting the motions to quash and dismissed the case, agreeing that the facts alleged did not constitute an offense under the law.
Municipal Court of Manila: Granted defendants' motions to quash the information on the ground that reckless imprudence is punishable only if the acts constitute a grave or less grave felony, not light felonies like slight physical injuries.
Supreme Court: Reversed the lower courts' decisions. Held that while Article 365 of the Revised Penal Code originally did not punish light felonies committed through reckless imprudence, the information's vague allegations of 'careless, reckless, negligent and imprudent manner' could encompass simple negligence, which is punishable for light felonies. Applied the principle that what is graver includes the lesser, allowing prosecution under simple negligence provisions. Remanded the case to trial court for hearing on the merits.