Jason Ivler y Aguilar v. Hon. Maria Rowena Modesto-San Pedro

Summary

This Supreme Court case established that reckless imprudence under Article 365 of the Revised Penal Code constitutes a single quasi-offense, regardless of multiple consequences. Jason Ivler, after being convicted of reckless imprudence resulting in slight physical injuries from a vehicular accident, successfully invoked double jeopardy to bar prosecution for reckless imprudence resulting in homicide and property damage arising from the same incident. The Court clarified that Article 48 (complex crimes) does not apply to quasi-offenses under Article 365, and that prosecution should proceed from a single charge regardless of the number or severity of consequences. The decision strengthened constitutional protection against double jeopardy in quasi-offense cases and resolved doctrinal confusion about the relationship between Articles 48 and 365 of the Revised Penal Code.