Francis O. Morales v. People

Summary

The Supreme Court En Banc affirmed Francis Morales' conviction for reckless imprudence resulting in multiple physical injuries and damage to property, but significantly modified the legal approach and penalties. The case arose from a 2013 vehicular accident where Morales overtook improperly and collided with a jeepney, injuring four passengers. Most importantly, the Court made a landmark ruling abandoning the People v. De los Santos precedent and definitively establishing that Article 48 (complex crimes) does not apply to quasi-crimes under Article 365. Following the Ivler doctrine, the Court ruled that reckless imprudence is a distinct crime requiring separate penalties for each consequence, not complex crime treatment. The Court corrected the penalty from imprisonment to public censure for the slight physical injuries (reclassified as light felonies) plus a P150,000 fine for property damage, establishing clearer guidelines for prosecuting and penalizing quasi-crimes.