A prior conviction for a quasi-offense under Article 365 of the Revised Penal Code, such as Reckless Imprudence Resulting in Slight Physical Injuries, bars a subsequent prosecution for another quasi-offense, like Reckless Imprudence Resulting in Homicide and Damage to Property, if both arise from the same act of reckless imprudence, because reckless imprudence is a single offense and prosecuting its multiple consequences separately violates the constitutional right against double jeopardy.

The case arose from a vehicular collision in August 2004 involving petitioner Jason Ivler and the vehicle of respondent Evangeline Ponce and her husband, Nestor C. Ponce. This incident led to injuries to Evangeline Ponce, the death of Nestor C. Ponce, and damage to the Ponces' vehicle.

• Following a vehicular collision in August 2004, petitioner Jason Ivler was charged before the Metropolitan Trial Court (MeTC) of Pasig City with two separate offenses: (1) Reckless Imprudence Resulting in Slight Physical Injuries (Criminal Case No. 82367) for injuries sustained by respondent Evangeline L. Ponce; and (2) Reckless Imprudence Resulting in Homicide and Damage to Property (Criminal Case No. 82366) for the death of respondent Ponce's husband Nestor C. Ponce and damage to their vehicle.
• Petitioner posted bail for his temporary release in both cases.
• On September 7, 2004, petitioner pleaded guilty to the charge in Criminal Case No. 82367 (Slight Physical Injuries) and was sentenced to public censure.
• Invoking this conviction, petitioner moved to quash the Information in Criminal Case No. 82366 (Homicide and Damage to Property) on the ground that it placed him in jeopardy of a second punishment for the same offense of reckless imprudence.
• The MeTC denied the motion to quash, finding no identity of offenses.
• Petitioner filed a petition for certiorari (S.C.A. No. 2803) with the Regional Trial Court (RTC) of Pasig City.
• Petitioner sought suspension of proceedings in Criminal Case No. 82366 at the MeTC, including his arraignment, due to the pending certiorari petition, but the MeTC proceeded with the arraignment.
• Due to petitioner's absence at the arraignment in Criminal Case No. 82366, the MeTC cancelled his bail and ordered his arrest.
• The RTC subsequently dismissed S.C.A. No. 2803, grounding its ruling on petitioner's forfeiture of standing due to his non-appearance at the MeTC arraignment, without reaching the merits of the double jeopardy claim.

• Petitioner argued that his non-appearance at the arraignment in Criminal Case No. 82366 did not divest him of standing to maintain his certiorari petition (S.C.A. No. 2803) before the RTC, as his petition was a pre-trial special civil action, not a post-conviction appeal.
• Petitioner contended that his constitutional right against double jeopardy barred his prosecution in Criminal Case No. 82366, as he had already been convicted in Criminal Case No. 82367 for the same offense of reckless imprudence arising from the same incident.
• Petitioner submitted that reckless imprudence is a single offense, and its multiple consequences (slight physical injuries, homicide, damage to property) are material only for determining the penalty, not for creating separate offenses.

• Respondent Ponce argued that the RTC correctly dismissed S.C.A. No. 2803 because petitioner forfeited his standing by not appearing at the arraignment in Criminal Case No. 82366.
• Respondent Ponce contended that there was no double jeopardy because light offenses (like slight physical injuries) cannot be complexed under Article 48 of the Revised Penal Code with grave or less grave felonies (like homicide).
• Respondent Ponce asserted that the prosecution was therefore obliged to file separate charges for Reckless Imprudence Resulting in Slight Physical Injuries and Reckless Imprudence Resulting in Homicide and Damage to Property.

• Whether petitioner forfeited his standing to seek relief in his certiorari petition (S.C.A. No. 2803) when the MeTC ordered his arrest following his non-appearance at the arraignment in Criminal Case No. 82366.
• Whether petitioner's constitutional right against double jeopardy bars further proceedings in Criminal Case No. 82366 for Reckless Imprudence Resulting in Homicide and Damage to Property, following his prior conviction for Reckless Imprudence Resulting in Slight Physical Injuries arising from the same incident.

• The Supreme Court held that petitioner's non-appearance at the arraignment in Criminal Case No. 82366 did not divest him of personality to maintain the petition in S.C.A. No. 2803. Dismissals of appeals due to an appellant's escape or violation of bail terms apply to reviews of convictions, not to pre-arraignment special civil actions challenging ancillary questions. Petitioner had also sought suspension of the MeTC proceedings prior to the scheduled arraignment.
• The Supreme Court ruled that petitioner's conviction in Criminal Case No. 82367 (Reckless Imprudence Resulting in Slight Physical Injuries) bars his prosecution in Criminal Case No. 82366 (Reckless Imprudence Resulting in Homicide and Damage to Property) due to double jeopardy.
• Reckless imprudence under Article 365 of the Revised Penal Code is a single crime. Its consequences on persons and property are material only to determine the penalty. The law penalizes the negligent or careless act, not the result thereof. As the careless act is single, the offense (criminal negligence) remains one and the same and cannot be split into different crimes and prosecutions.
• Article 48 of the Revised Penal Code, which deals with complex crimes, does not apply to acts penalized under Article 365. Article 48 is conceptually incongruent with quasi-offenses because it is impossible for a quasi-offense to constitute two or more grave or less grave felonies, or for one offense to be a necessary means for committing another in the context of negligence.
• Prosecutions under Article 365 should proceed from a single charge regardless of the number or severity of the consequences. Only one information should be filed, and the judge will apply the penalties under Article 365 for each consequence alleged and proven. This approach prevents constitutionally impermissible second prosecutions and conserves state resources.
• The petition was GRANTED. The RTC Orders were REVERSED, and the Information in Criminal Case No. 82366 was DISMISSED on the ground of double jeopardy.

• Double Jeopardy (Constitutional Right) — Section 21, Article III of the 1987 Constitution protects an accused from being "twice put in jeopardy of punishment for the same offense." This doctrine was applied to bar the second prosecution of petitioner for Reckless Imprudence Resulting in Homicide and Damage to Property because he had already been convicted for Reckless Imprudence Resulting in Slight Physical Injuries, both charges arising from the single act of reckless imprudence.
• Reckless Imprudence as a Single Quasi-Offense (Article 365, RPC) — Article 365 of the Revised Penal Code defines and penalizes quasi-offenses. The Court reiterated the doctrine established in Quizon v. Justice of the Peace of Pampanga that reckless imprudence is a distinct crime in itself, penalizing the mental attitude or condition behind the act (the dangerous recklessness, lack of care, or foresight), not the various resulting acts of damage or injury. In this case, the Court held that the petitioner's single act of reckless driving constituted only one offense of reckless imprudence, and the different consequences (slight physical injuries to one person, homicide of another, and damage to property) do not transform it into multiple offenses but are only considered in determining the penalty.
• Non-applicability of Article 48 (Complex Crimes) to Article 365 (Quasi-Offenses) — Article 48 of the Revised Penal Code, which allows for the complexing of crimes when a single act constitutes two or more grave or less grave felonies, or when an offense is a necessary means for committing another, is conceptually incompatible with Article 365. The Court ruled that Article 48 cannot be applied to quasi-offenses because a single act of imprudence results in a single quasi-crime, and the varying severities of its consequences do not lend themselves to the complex crime framework designed for intentional felonies. Therefore, splitting charges based on the inability to complex light offenses with graver ones under Article 48 is erroneous when dealing with quasi-offenses under Article 365.
• Prosecution of Quasi-Offenses under a Single Charge — The Court established that all consequences of a single act of reckless imprudence under Article 365 must be prosecuted under a single information, regardless of their number or severity. Penalties for each proven consequence will be imposed separately according to the scheme in Article 365. This ruling ensures protection against double jeopardy and promotes efficient use of state resources.

• "Reckless Imprudence is a Single Crime, its Consequences on Persons and Property are Material Only to Determine the Penalty."
• "The law penalizes thus the negligent or careless act, not the result thereof. The gravity of the consequence is only taken into account to determine the penalty, it does not qualify the substance of the offense. And, as the careless act is single, whether the injurious result should affect one person or several persons, the offense (criminal negligence) remains one and the same, and can not be split into different crimes and prosecutions." (Quoting People v. Buan)
• "Article 48 is incongruent to the notion of quasi-crimes under Article 365. It is conceptually impossible for a quasi-offense to stand for (1) a single act constituting two or more grave or less grave felonies; or (2) an offense which is a necessary means for committing another."
• "Hence, we hold that prosecutions under Article 365 should proceed from a single charge regardless of the number or severity of the consequences. In imposing penalties, the judge will do no more than apply the penalties under Article 365 for each consequence alleged and proven. In short, there shall be no splitting of charges under Article 365, and only one information shall be filed in the same first level court."

• Quizon v. Justice of the Peace of Pampanga — Referenced as establishing the doctrine that reckless imprudence is a distinct crime in itself, not merely a way of committing other crimes. This conceptualization underpins the ruling that all consequences of a single negligent act constitute only one offense.
• People v. Diaz — Cited as the beginning of an "unbroken chain of jurisprudence" applying the Double Jeopardy Clause to Article 365, holding that conviction or acquittal of reckless imprudence bars subsequent prosecution for the same quasi-offense, regardless of its various resulting acts.
• People v. Buan — Heavily relied upon for its articulation that in reckless imprudence, the law penalizes the negligent act, not its result, and that a single careless act constitutes a single offense which cannot be split into different crimes and prosecutions. This case also rejected the argument that Article 48's complex crime rules prevent joining charges for different consequences of reckless imprudence.
• People v. Silva — Cited as a direct progeny of Diaz and analogous to Ivler's case, where an acquittal for "Slight Physical Injuries thru Reckless Imprudence" barred a subsequent prosecution for "Homicide with Serious Physical Injuries thru Reckless Imprudence" arising from the same vehicular collision. The Court in Silva affirmed the trial court's dismissal on grounds of double jeopardy.
• El Pueblo de Filipinas v. Estipona — Mentioned as the "only one ruling going against this unbroken line of authority" (prior to Buerano). Estipona allowed subsequent prosecution despite a prior conviction arising from the same reckless act. The Court noted that Estipona was impliedly overruled by the Diaz line and effectively overruled by Buerano.
• Buerano v. Court of Appeals — Cited as having "effectively overruled Estipona." Buerano reversed a Court of Appeals decision that relied on Estipona, reaffirming the Buan doctrine on double jeopardy in reckless imprudence cases.
• Angeles v. Jose — Referenced in the discussion of the "second jurisprudential path" which nixes Article 48 and sanctions a single prosecution for all effects of a quasi-crime, penalizing each consequence separately under Article 365. This case interpreted the third paragraph of Article 365 as requiring an additional penalty for physical injuries if there is also damage to property, implying a single information.
• People v. Faller — Mentioned as a contrary doctrinal pronouncement (that reckless imprudence is not a crime in itself but a way of committing it) that was abandoned when the Court en banc promulgated Quizon.

• Article 365 of the Revised Penal Code — This is the central provision defining and penalizing quasi-offenses (imprudence and negligence). The Court's entire analysis revolves around the nature of crimes under this article, concluding they are single offenses regardless of multiple consequences, with penalties determined by those consequences.
• Article 48 of the Revised Penal Code — This article on complex crimes (when a single act constitutes two or more grave or less grave felonies, or when an offense is a necessary means for committing another) was held to be inapplicable and conceptually incongruent with quasi-offenses under Article 365.
• Section 21, Article III, 1987 Constitution — This is the Double Jeopardy Clause ("No person shall be twice put in jeopardy of punishment for the same offense."). It was the primary constitutional basis for barring the second prosecution against the petitioner.
• Section 8, Rule 124 of the Revised Rules on Criminal Procedure — This rule, concerning dismissal of appeal for abandonment or escape, was cited to distinguish petitioner's situation (a pre-arraignment special civil action) from cases where an appellant's appeal of a conviction is dismissed due to escape.
• Section 1, Rule 125 of the Revised Rules on Criminal Procedure — Referenced in conjunction with Rule 124, Section 8, regarding the dismissal of appeals when an appellant escapes or jumps bail.
• Section 21, Rule 114 of the Revised Rules of Criminal Procedure — This rule on forfeiture of bail was cited to show that a defendant's non-appearance at a hearing merely renders the bondsman liable and can lead to trial in absentia, but does not ipso facto convert the accused into a fugitive without standing for all purposes, especially for pre-trial remedies.
• Section 7, Rule 117 of the Revised Rules of Criminal Procedure — This rule, on former conviction or acquittal or double jeopardy as a ground to quash an information, was implicitly the procedural basis for petitioner's motion to quash.
• Republic Act No. 7691 — Mentioned in the context that under this law, the MeTC now has exclusive original jurisdiction to impose the most serious penalty under Article 365 (prision correccional in its medium period), relevant to the discussion on splitting charges between first and second level courts.