Tuesday, May 4, 2021

Case Digest: Marie Beth Revilla / IVLER VS. HON. MODESTO G.R. No. 172716 : November 17, 2010

 

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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