- Petitioner
- Marcelino M. Dela Cruz
- Respondent
- People
- Citation
- G.R. No. 219038
- Court
- Supreme Court
- Division
- First Division
- 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.