- Petitioner
- People
- Respondent
- Medroso
- Citation
- G.R. No. L-37633
- Court
- Supreme Court
- Decided
- January 31, 1975
Whether mitigating circumstances should reduce the penalty for homicide through reckless imprudence under Article 365 of the Revised Penal Code, and…
Summary
Felicisimo Medroso, Jr. was convicted of homicide through reckless imprudence for fatally hitting a pedestrian while driving without a license. He pleaded guilty and claimed entitlement to penalty reduction under Article 64 due to mitigating circumstances. The Supreme Court ruled that Article 365 paragraph 5 grants courts discretionary sentencing power without regard to Article 64's mathematical formula, even with mitigating circumstances present. The Court modified only the minimum term (reducing by one day to comply with Indeterminate Sentence Law) and affirmed the damage awards. This case establishes that quasi-offenses under Article 365 allow judicial discretion in penalty imposition, recognizing that negligence varies in nature and consequences, requiring flexible rather than rigid sentencing rules.
Focus of dispute
Whether mitigating circumstances should reduce the penalty for homicide through reckless imprudence under Article 365 of the Revised Penal Code, and the proper application of the Indeterminate Sentence Law
Legal facts
On May 16, 1971, in Bombon, Camarines Sur, accused Felicisimo Medroso, Jr. drove a BHP dump truck without a license and negligently hit pedestrian Inigo Andes, causing his death. Accused pleaded guilty with two mitigating circumstances: plea of guilty and voluntary surrender. Trial court considered driving without license as aggravating circumstance and sentenced him to 2 years, 4 months, 1 day minimum to 6 years maximum of prision correccional, plus damages of P12,000 actual, P4,000 moral, and P4,000 exemplary damages.
Judgement and reasoning
Court of Appeals: Certified the case to the Supreme Court on September 19, 1973, determining that the appeal involved pure questions of law.
Court of First Instance of Camarines Sur: Convicted accused of homicide through reckless imprudence, appreciated mitigating circumstances of guilty plea and voluntary surrender, considered driving without license as aggravating circumstance, and sentenced accused to indeterminate penalty of 2 years, 4 months, 1 day minimum to 6 years maximum of prision correccional, plus damages totaling P20,000.
Supreme Court: Modified the trial court decision by reducing the minimum term by one day, ruling that Article 365 paragraph 5 allows courts discretionary sentencing without regard to Article 64 rules, even with mitigating circumstances present. Affirmed damage awards as proper. Final sentence: 2 years, 4 months minimum to 6 years maximum of prision correccional, plus damages.