Hedy Gan y Yu v. Court of Appeals

Summary

Hedy Gan was charged with Homicide through Reckless Imprudence after hitting and killing pedestrian Isidoro Casino while avoiding an oncoming vehicle that encroached her lane. The trial court convicted her of the charged offense, while the Court of Appeals modified this to Simple Imprudence. The Supreme Court reversed both lower courts, applying the emergency rule doctrine. The Court found that Gan faced an imminent danger requiring immediate action without time for reflection, and that the emergency was not caused by her own negligence. Since she was driving within legal limits and had to make a split-second decision to avoid collision, she could not be held criminally liable. The Court also set aside the civil indemnity as the victim's heirs had waived their claim through a release document.