People v. Benigno Lingad y Vito · G.R. L-10952

Petitioner: People
Respondent: Benigno Lingad y Vito
Citation: G.R. No. L-10952
Court: Supreme Court
Division: En Banc
Ponente: Bautista Angelo, J.
Decided: May 30, 1958

Whether slight physical injuries committed through reckless imprudence is punishable under Philippine criminal law, specifically under Article 365 of…

Summary

This Supreme Court case clarified the scope of criminal liability under Article 365 of the Revised Penal Code regarding negligent acts causing physical injuries. Defendant Benigno Lingad was charged with slight physical injuries through reckless imprudence after a vehicular accident that injured Mayor Arsenio Lacson. The Court of First Instance dismissed the case, ruling that such acts are not punishable under Philippine law. However, the Supreme Court En Banc reversed this decision, holding that informations alleging reckless imprudence can encompass simple negligence, which is punishable under Article 365. The Court applied the principle that greater offenses include lesser ones, allowing prosecution to proceed based on evidence that may prove simple rather than reckless negligence. This decision established important precedent regarding the interpretation of criminal negligence provisions and the sufficiency of criminal informations in cases involving varying degrees of imprudence.

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Reckless Imprudence in the Philippines

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By Intellegal Editorial Board · May 30, 1958

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