Facts:
Francis O. Morales, the driver of a Mitsubishi Delica Van, was involved in a vehicular accident on May 14, 2013, in Angeles City, leading to charges against him for the crime of Reckless Imprudence Resulting in Damage to Property and Multiple Physical Injuries. Morales pleaded not guilty, and the case proceeded through the Municipal Trial Court in Cities (MTCC), Regional Trial Court (RTC), and Court of Appeals (CA), each affirming his conviction with varying modifications on penalties and damages awarded. Morales sought reconsideration from the Supreme Court, arguing issues on the Traffic Accident Report, misapplication of law in determining negligence, and imposition of penalties and damages.
Issues:
1. Whether Morales was negligent in causing the vehicular accident resulting in damage to property and physical injuries.
2. The applicability of the “last clear chance” doctrine.
3. The correctness of the imposition of the penalty by the CA under Section 97 of R.A. No. 10951.
4. The award of damages, specifically temperate damages in lieu of actual damages.
Court’s Decision:
The Supreme Court affirmed Morales’s conviction for reckless imprudence but modified the penalty imposed. The Court clarified that reckless imprudence constitutes a distinct offense and upheld the penalties based on the consequences of Morales’s actions, emphasizing the “Ivler Doctrine” that forbids the complexing of quasi-crimes under Article 365 of the Revised Penal Code. The penalty imposed was based on the consequences being classified as slight physical injuries (requiring hospitalization for 1-9 days) and damage to property, with the application of temperate damages due to the inability to substantiate the actual amount spent for repairs.
Doctrine:
This case reiterates the principle that reckless imprudence constitutes a unique offense under Article 365 of the Revised Penal Code, distinct from merely being a modality of committing crimes. It underscores the prohibition against “complexing” quasi-offenses and their resulting acts under Article 48 of the Revised Penal Code, emphasizing a singular prosecution for all effects of a quasi-crime, regardless of their severity or number.
Class Notes:
1. **Reckless Imprudence (Article 365, RPC)** – Defined as performing or failing to perform an act, without malice, where such act or omission causes damage due to inexcusable lack of precaution.
2. **”Last Clear Chance” Doctrine** – Not applicable when one party is clearly found negligent and the other party did not have the opportunity to avoid the consequence.
3. **Section 97 of R.A. No. 10951** – Adjusts the penalties for crimes in accordance with the inflation rate and current values.
4. **Temperate Damages (Article 2224, New Civil Code)** – Can be awarded when some pecuniary loss has been suffered but its exact amount cannot be proved with certainty.
Historical Background:
This case highlights the evolving jurisprudence on the interpretation of reckless imprudence under Philippine law, emphasizing the distinction between quasi-offenses and intentional crimes, which has implications on the prosecution and penalties of such offenses.
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