**Facts:**
1. **Incident:** On September 12, 1999, in Angat, Bulacan, Reynaldo S. Mariano, driving a red Toyota pick-up, overtook and almost collided with Ferdinand de Leon’s jeep. Following an altercation, both parties went separate ways. However, later that evening, Mariano’s pick-up sideswiped de Leon, causing severe injuries.
2. **Charges Filed:** The Provincial Prosecutor of Bulacan charged Mariano with frustrated murder for intentionally hitting de Leon.
3. **Trial Court Proceedings:** Mariano was convicted of the lesser offense of frustrated homicide by the Regional Trial Court (RTC) of Malolos, Bulacan, Branch 81. He was sentenced to three years and four months of prision correccional to six years and one day of prision mayor.
4. **Court of Appeals:** Mariano appealed, and the Court of Appeals (CA) modified the conviction to reckless imprudence resulting in serious physical injuries, imposing a penalty of two months and one day of arresto mayor, to one year, seven months and eleven days of prision correccional.
5. **Supreme Court Review:** Mariano further appealed to the Supreme Court, asserting that his guilt was not proven beyond reasonable doubt, the injuries being accidental, and that voluntary surrender should be considered a mitigating circumstance.
**Issues:**
1. Whether Mariano’s actions constituted reckless imprudence resulting in serious physical injuries rather than frustrated homicide.
2. Whether voluntary surrender should be appreciated as a mitigating circumstance.
3. Whether the penalty imposed by the CA was appropriate.
**Court’s Decision:**
1. **Reckless Imprudence vs. Frustrated Homicide:** The Supreme Court affirmed the CA’s finding of reckless imprudence resulting in serious physical injuries. The Court held that speeding beyond normal rates and failing to foresee that Ferdinand might alight from his jeep constituted reckless imprudence.
2. **Mitigating Circumstance:** The Supreme Court held that the mitigating circumstance of voluntary surrender could not be appreciated in Mariano’s favor. Article 365 of the Revised Penal Code allows courts discretion in imposing penalties without regard to the rules in Article 64, thus, overriding the potential application of mitigating circumstances.
3. **Correct Penalty:** The Supreme Court found that the CA erred in imposing the penalty suitable for a grave felony. Given that Ferdinand’s injuries would have constituted a less grave felony under Article 263, paragraph 3 of the Revised Penal Code, the correct penalty was arresto mayor in its minimum and medium periods. Thus, the Court imposed a straight penalty of two months of arresto mayor.
**Doctrine:**
1. **Reckless Imprudence:** The essence of reckless imprudence is the voluntary, albeit unintentional, commission of an act from which material damage results due to inexcusable lack of precaution.
2. **Judicial Discretion in Penalty Imposition:** Courts have discretion in imposing penalties for quasi-offenses under Article 365 of the Revised Penal Code and are not bound by the rules for mitigating and aggravating circumstances outlined in Article 64.
**Class Notes:**
1. **Reckless Imprudence (Article 365, Revised Penal Code):** Voluntary commission of an act without malice from which material damage results due to inexcusable lack of precaution.
2. **Grave, Less Grave, and Light Felonies (Article 9, Revised Penal Code):** Differentiated based on the severity of the penalty imposed.
3. **Penalties (Article 25, Revised Penal Code):** Categories of penalties – afflictive, correctional, and light.
4. **Serious Physical Injuries (Article 263, Revised Penal Code):** Classification of injuries by severity and corresponding penalties.
5. **Voluntary Surrender (Article 13(7), Revised Penal Code):** A mitigating circumstance that may be considered at the court’s discretion in quasi-offenses.
**Historical Background:**
The case reflects the Philippine judiciary’s approach to traffic-related offenses, emphasizing the careful imposition of penalties and the differentiation between intentional harm and negligence. It underscores the inherent judicial discretion in applying mitigating factors and highlights the importance of driving prudence to prevent harm.
This case also marks a significant interpretation regarding reckless imprudence in vehicular accidents, setting a benchmark for future cases involving similar facts and legal contexts.
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