**Facts:**
– **Date & Location of Incident:** 28 December 2004, Brgy. Maslog, Sibulan, Negros Oriental.
– **Incident:** Petitioner Jeffrey Reso Dayap was driving a 10-wheeler cargo truck loaded with coconut shells. The truck collided with a Colt Galant, causing the death of Lou Gene R. Sendiong, injuries to passengers Dexie Duran and Elvie Sy, and damage to the vehicle.
– **Information Filing:** 29 December 2004, Provincial Prosecutor’s Office charged Dayap with Reckless Imprudence resulting in Homicide, Less Serious Physical Injuries, and Damage to Property.
– **Arraignment:** 10 January 2005, Dayap pleaded not guilty before the MTC of Sibulan, Negros Oriental.
– **Motion for Leave:** 17 January 2005, respondents filed a motion to amend the information to include abandonment of the victims.
– **Motion Withdrawal:** 21 January 2005, Provincial Prosecutor filed an Omnibus Motion to withdraw the motion to amend. MTC granted the withdrawal.
– **Trial:** Prosecution rested its case. Dayap filed a Demurrer to Evidence arguing insufficient evidence.
– **Demurrer to Evidence:** 15 April 2005, filed by Dayap.
– **MTC Decision:** 16 May 2005, granted the Demurrer, acquitted Dayap, noted prosecution’s failed evidence presentation.
– **Certiorari Petition:** Respondents filed with RTC alleging MTC’s failure to consider prosecution evidence and properly conduct trial per Sec. 11, Rule 119 of the Rules of Court.
– **RTC Decision:** 23 August 2005, affirmed MTC’s acquittal but remanded the case to MTC for determining civil liability.
– **Motions for Reconsideration:** Both parties filed motions which were denied by RTC on 12 September 2005.
**Issues:**
1. **Jurisdiction of the Court:** Whether the Court of Appeals erred in ruling that jurisdiction over the offense charged pertained to the RTC.
2. **Remand for Civil Liability:** Whether the trial court erred in remanding the case for the determination of the civil aspect after acquittal.
**Court’s Decision:**
1. **Jurisdiction of the Offense:**
– **Legal Analysis:** Under R.A. No. 7691, MTCs have jurisdiction over all offenses punishable with imprisonment not exceeding 6 years, including those involving damage to property through criminal negligence. Dayap was charged under Article 365, punishable by prision correccional, falling within MTC’s jurisdiction.
– **Conclusion:** The Court of Appeals erred. The MTC of Sibulan had proper jurisdiction, and the RTC did not have original jurisdiction.
2. **Remand for Civil Liability:**
– **Legal Analysis:** While acquittal in criminal cases does not preclude civil action unless the court declares that the act from which civil liability may arise did not exist, the detailed findings of fact by MTC established that no crime or negligence by the petitioner was proven.
– **Conclusion:** There was no need to remand for determining civil liability as MTC’s acquittal findings sufficiently negated all elements of civil liability.
**Doctrine:**
– **Jurisdiction Rule:** Jurisdiction over offenses under Article 365 of the Revised Penal Code when punishable with prision correccional lies with the MTC under R.A. No. 7691.
– **Impact of Acquittal:** If factual determination in acquittal confirms no crime or negligence was committed, civil liability is extinguished.
**Class Notes:**
– **Key Elements of Reckless Imprudence:**
1. Reckless imprudence causing grave or less grave felony.
2. Establishment of fault or negligence as the proximate cause.
3. Penal consequences (e.g., prision correccional).
– **Relevant Statutes:**
– *Article 365, Revised Penal Code*: Penalizes reckless imprudence.
– *R.A. No. 7691:* Extends the jurisdiction of first-level courts.
– **Court Procedures:** Demurrer to evidence, Sec. 11 & 23, Rule 119, Rules of Court.
**Historical Background:**
– **Legal Context:** Jurisdiction over criminal cases, including complex crimes like reckless imprudence with multiple felonious consequences, can be complex and has evolved over time. The enactment of R.A. No. 7691 was crucial in re-allocating jurisdiction to enable first-level courts to handle cases involving prision correccional.
– **Case Precedent:** This case reiterates the critical analysis required in determining proper jurisdiction and the implications of acquittal on civil liabilities post-trial. It also underscores procedural adherence to rule-based evidence assessment in criminal proceedings.
Leave a Reply