IVLER VS. HON. MODESTO
G.R. No. 172716 : November
17, 2010
FACTS:
Regarding a vehicular accident in August 2004,
petitioner Jason Ivler was charged with two separate crimes before the
Metropolitan Trial Court of Pasig City:
(1) reckless imprudence resulting in slight
physical injuries for injuries sustained by respondent Evangeline L. Ponce; and
(2) reckless imprudence resulting in homicide and damage to property for the
death of respondent Ponce’s husband Nestor C. Ponce and damage to the spouses
Ponce’s vehicle.
Ivler pled guilty to
reckless imprudence resulting in minor physical injury on September 7, 2004,
and received a public censure as a result. Invoking this conviction, Ivler
filed a motion to quash the Information of reckless imprudence resulted in
homicide and property harm, claiming that it placed him in danger of receiving
a second sentence for the same reckless imprudence crime.
ISSUE:
Whether or not The
Double Jeopardy Clause, which protects Ivler's civil rights, prevents
additional litigation in the information charging him with careless imprudence
resulting in homicide and property loss.
RULING:
Yes, the Supreme Court
reversed the RTC's ruling. Petitioner's conviction for negligent imprudence
causing minor bodily harm prohibits him from facing charges of aggravated
reckless imprudence causing homicide and property damage. Reckless imprudence
is a single crime, and the effects for people and property are only relevant in
determining the punishment. The two charges brought against the complainant
arose from the same evidence and were tried under the same clause of the RPC,
as amended, namely Article 365, which defines and punishes quasi-criminals. The
RPC's Art 3 suggests that "reckless imprudence" is not a felony in
and of itself, but rather a method of committing it. Reckless Imprudence
convictions or acquittals preclude prosecution on the same quasi-offense in the
future. According to the Court, whether the accused is guilty or cleared of a
single act of reckless imprudence, the accused can not be tried for the same
act again. The seriousness of the outcome is only considered when determining
the penalty; it has no bearing on the nature of the offence.
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