**Facts:**
On the morning of June 25, 1997, Dionesio Inguito, Sr., along with his two minor children, was involved in a vehicular accident in Don Carlos, Bukidnon. While ascending a curve, their motorcycle was hit head-on by a Toyota Land Cruiser driven by Rogelio J. Gonzaga, who was on the wrong side of the road. The collision resulted in the death of Dionesio Sr. and serious injuries to his children. Gonzaga did not immediately provide aid to the victims. Subsequently, an Information was filed against Gonzaga for Reckless Imprudence Resulting to Homicide with Double Serious Physical Injuries and Damage to Property under the Revised Penal Code (RPC). Gonzaga pled not guilty, claiming a mechanical failure prevented him from aiding the victims immediately and contended it was Dionesio Sr. who was recklessly driving. The Regional Trial Court (RTC) of Malaybalay City, Bukidnon, found Gonzaga guilty, a decision which he appealed. The Court of Appeals (CA) affirmed the RTC’s decision, which led Gonzaga to file a petition for review on certiorari with the Supreme Court.
**Issues:**
1. Whether or not Gonzaga’s act of driving on the wrong side of the road at a high speed constituted reckless imprudence resulting in homicide, serious physical injuries, and property damage.
2. Whether or not Gonzaga failed to provide immediate assistance to the injured parties, warranting the imposition of a higher penalty.
**Court’s Decision:**
The Supreme Court denied the petition, affirming the CA’s decision but modified the penalties. It held Gonzaga criminally liable, emphasizing reckless imprudence in driving at a fast speed on the wrong side approaching a curve. However, it acknowledged Gonzaga’s attempt at assistance post-accident, adjusting the penalty accordingly. He was sentenced to an indeterminate penalty of two years of prision correccional as a minimum to six years as a maximum. The Court clarified that the award for the death of Dionesio Sr. was denominated as “civil indemnity” instead of “moral damages.”
**Doctrine:**
The Supreme Court highlighted the principles surrounding reckless imprudence under Article 365 of the RPC, particularly focusing on the voluntary but careless execution of an act without malice, leading to material damage due to inexcusable lack of precaution.
**Class Notes:**
– **Reckless Imprudence (Article 365, RPC):** Involves performing or failing to perform an act, resulting in material damage due to an inexcusable lack of precaution considering the actor’s occupation, intelligence, physical condition, and the context of time, place, and people.
– **Causal Connection:** For motorist liability in negligence cases, a direct causal link must be established between the negligence and the resultant damages.
– **Aid to Injured Parties:** The penal law imposes a higher penalty on offenders who fail to lend on-the-spot assistance to the injured, which is conditioned on the offender’s capability of providing help at the moment.
**Historical Background:**
This case exemplifies the judiciary’s stance on vehicular accidents due to reckless imprudence in the Philippines. It underscores the responsibility of drivers to exercise caution, especially on challenging road conditions like curves, and the obligation to render aid to accident victims whenever possible. Through this judgment, the Supreme Court reinforces the critical nature of road safety and the legal implications of failing to uphold it.
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