Article 365 of the Revised Penal Code punishes reckless imprudence as a distinct crime, not merely as a way of committing a crime. Consequently, Article 48 of the RPC (on complex crimes) does not apply to quasi-crimes. When a single act of reckless imprudence results in multiple consequences, such as physical injuries and damage to property, separate penalties must be imposed for each consequence: a penalty for the physical injuries based on their severity (grave, less grave, or light felony had they been intentional) and a fine for the damage to property, as prescribed under Article 365.

The case arose from a vehicular collision on May 14, 2013, in Angeles City. Petitioner Francis O. Morales, driving a Mitsubishi Delica Van, overtook another vehicle and collided with an Isuzu Jitney driven by Rico Mendoza. The collision resulted in physical injuries to Rico Mendoza, Lailani Mendoza, Myrna Cunanan, and Albert Vital (passengers of the jeepney), and extensive damage to the jeepney owned by Noel G. Garcia.

• On May 14, 2013, around 3:00 a.m., petitioner Francis O. Morales was driving his Mitsubishi Delica Van along Sto. Rosario St., Angeles City, going towards San Fernando.
• Rico Mendoza was driving a passenger jeepney (owned by Noel G. Garcia) on the opposite lane, on its rightful right lane, heading towards Angeles City Market, with passengers Lailani Mendoza, Myrna Cunanan, and Albert Vital.
• Petitioner, driving at a fast speed, suddenly overtook the vehicle in front of him, thereby occupying the lane of the jeepney driven by Rico.
• Rico attempted to avoid the collision but was unsuccessful, and petitioner's van bumped the jeepney.
• The collision resulted in physical injuries to Rico (deep laceration in forehead, cervical strain), Lailani Mendoza (skin and soft tissue avulsion, sprain ankle), Myrna Cunanan (multiple physical injuries), and Albert Vital. It also caused extensive damage to the jeepney, estimated at P350,000.00.
• Petitioner countered that he was on the inner lane bound for San Fernando City when the right side of the jeepney suddenly hit his Delica van. He and his son were also injured.
• The Traffic Accident Report (TAR) and a sketch plan indicated the point of impact was on the inner lane occupied by the jeepney.

• The CA erred in giving full faith and credence to the Traffic Accident Report (TAR), which was allegedly prepared without his presence and at the instance of private complainants.
• Object evidence (physical depression on vehicles) showed Rico steered the jeepney into the van's direction; the point of impact was within petitioner's lane.
• Rico was negligent as he saw the approaching van but did not evade it, having the last clear chance.
• The prosecution failed to establish the actual speed of petitioner's vehicle and that Rico was driving with due diligence.
• The award of temperate damages has no basis as petitioner was not shown to be negligent, and private complainants failed to prove substantial pecuniary losses or earning capacity.
• The CA erroneously applied Section 97 of R.A. No. 10951 to increase his penalty, as R.A. No. 10951 (passed in 2017) should not be applied retroactively if not favorable to him, the infraction being committed in 2013.

• The courts a quo correctly found that the prosecution established all elements of the crime charged.
• The MTCC's finding of guilt was based on evidence that petitioner overtook without checking if the opposite lane was clear, on a dark, not well-lighted road, and driving at a fast speed.
• The RTC based its ruling on a sketch showing the impact occurred at the inner lane occupied by the private complainants' jeepney.
• The CA anchored its findings on the unrebutted presumption of negligence as petitioner was violating a traffic regulation (driving on the wrong side of the road) during the mishap, not solely on the TAR.
• The award of damages was in conformity with prevailing jurisprudence.

• Whether the petitioner's conviction for reckless imprudence resulting in multiple physical injuries and damage to property should be upheld.
• Whether Article 48 of the Revised Penal Code (complex crimes) applies to quasi-crimes under Article 365 of the RPC.
• How penalties under Article 365 of the RPC should be imposed when a single act of reckless imprudence results in both physical injuries and damage to property.
• Whether R.A. No. 10951 was correctly applied by the CA in determining the penalty.

• The Supreme Court DENIED the petitioner's Motion for Reconsideration and AFFIRMED his conviction with MODIFICATION of the penalty.
• The Court held that petitioner was guilty beyond reasonable doubt of reckless imprudence resulting in multiple slight physical injuries and damage to property. His act of overtaking without ensuring the road was clear, thereby encroaching on the opposite lane and causing the collision, constituted inexcusable lack of precaution.
• The Court definitively ruled that the Ivler v. Hon. Judge Modesto-San Pedro doctrine is good law and abandoned the contrary ruling in People v. De los Santos. Reckless imprudence under Article 365 of the RPC is a distinct crime, and Article 48 of the RPC (complex crimes) is inapplicable to quasi-crimes.
• For the multiple slight physical injuries sustained by Rico Mendoza, Leilani Mendoza, and Myrna Cunanan, the Court imposed the penalty of public censure for each injury. This is because slight physical injuries is a light felony, and under Article 365, if the penalty for the intentional felony is equal to or lower than that provided in the first two paragraphs of Article 365, the penalty next lower in degree (public censure, being next lower to arresto menor) shall be imposed.
• For the damage to property, the Court ordered petitioner to pay a fine of P150,000.00, which is equivalent to the temperate damages awarded for the jeepney, consistent with the third paragraph of Article 365.
• Temperate damages were affirmed: P8,000.00 to Spouses Rico and Leilani Mendoza, P2,000.00 to Myrna Cunanan, and P150,000.00 to Noel G. Garcia for the jeepney, as pecuniary loss was suffered though its exact amount was not proven.
• All monetary awards shall earn 6% interest per annum from the finality of the Resolution until fully paid.

• Reckless Imprudence as a Distinct Crime (Ivler Doctrine) — Reckless imprudence under Article 365 of the RPC is not merely a way of committing a crime but is a crime in itself. The object of punishment in quasi-crimes is the mental attitude or condition behind the act (dangerous recklessness, lack of care or foresight). This doctrine means that Article 48 of the RPC (complex crimes) is inapplicable to quasi-crimes. The Court affirmed this doctrine, abandoning People v. De los Santos, and held that a single information should be filed for all consequences of a single imprudent act, but separate penalties are imposed for each consequence.
• Penalties under Article 365, RPC — When a single act of reckless imprudence results in both damage to property and physical injuries, separate penalties are imposed: a fine for the damage to property (ranging from an amount equal to the value of said damages to three times such value, but not less than P5,000), and an additional penalty for the physical injuries based on their severity had they been intentional. The Court applied this by imposing public censure for each slight physical injury and a fine for the damage to property.
• Presumption of Negligence (Article 2185, New Civil Code) — A person driving a motor vehicle is presumed negligent if at the time of the mishap, he was violating any traffic regulation. The Court noted petitioner was driving on the wrong side of the road at the time of the collision, and he failed to rebut this presumption.
• Last Clear Chance Doctrine — This doctrine presupposes that both parties are negligent, but the negligent act of one is appreciably later in time than that of the other, or where it is impossible to determine whose negligence caused the incident, the one who had the last clear opportunity to avoid the harm but failed to do so is chargeable. The Court found this inapplicable as the evidence showed petitioner was at fault.
• Jurisdiction over Quasi-Crimes (BP 129, as amended by RA 7691) — First-level courts (MeTCs, MTCs, MCTCs, MTCCs) have exclusive original jurisdiction over criminal negligence cases resulting in damage to property, regardless of the fine, and over all offenses punishable with imprisonment not exceeding six years. The Court affirmed that the MTCC correctly took cognizance of the case.
• Retroactive Application of Penal Laws — Penal laws shall have a retroactive effect insofar as they favor the person guilty of a felony. The Court did not explicitly discuss petitioner's argument on R.A. 10951's application in the penalty section but ultimately imposed public censure based on the existing structure of Article 365 and the nature of slight physical injuries. The CA had applied R.A. 10951 for the arresto mayor penalty. The Supreme Court's final penalty of public censure for the slight physical injuries stemmed from the specific provision in Article 365 (sixth paragraph) concerning penalties equal to or lower than those in the first two paragraphs.

• "We rule that Ivler is a good law, notwithstanding the few stray cases that allowed the 'complexing' of the effects of a single quasi-offense. Forbidding the application of Article 48 of the RPC to quasi-offenses and their resultant acts/effects preserves the conceptual distinction between quasi-crimes and intentional felonies under the RPC. We thus declare that De los Santos is abandoned. We agree with Our pronouncements in Ivler. Article 48 does not apply to quasi-offenses under Article 365 because reckless imprudence is a distinct crime and not a mere way of committing a crime. Simple or reckless imprudence does not strictly fall under the term 'felonies' or acts or omissions committed by fault or culpa."
• "The correct approach is to impose separate penalties for each consequence of the imprudent act alleged and proven."
• "Thus, the proper penalty for reckless imprudence resulting in slight physical injuries is public censure, this being the penalty next lower in degree to arresto menor."

• Ivler v. Hon. Judge Modesto-San Pedro (2010) — Cited as the controlling doctrine establishing that reckless imprudence is a distinct crime and Article 48 RPC is inapplicable to quasi-crimes. The Court affirmed Ivler.
• People v. De los Santos (2001) — An En Banc case holding that Article 48 RPC applies to crimes through negligence. The Court explicitly abandoned this ruling.
• Angeles v. Jose (1954) — Cited for the interpretation that the third paragraph of Article 365 (fine for damage to property) applies even if there are also physical injuries, with an additional penalty for the latter. The Court found this interpretation conforms with the Ivler doctrine of imposing separate penalties for each consequence.
• Quizon v. The Justice of the Peace of Pampanga (1955) — Cited as the bedrock of Ivler's dicta that simple or reckless imprudence are distinct species of crime, where what is penalized is the mental attitude or condition behind the act.
• Reodica v. Court of Appeals (1998) — Distinguished. Reodica held that the third paragraph of Article 365 applies only if damage to property only resulted. The current ruling follows Angeles and Ivler, stating the fine applies even with other injuries.
• Esteban v. People (2017) — Cited as a recent case that correctly applied the Ivler doctrine by imposing separate penalties for homicide, serious physical injuries, and damage to property resulting from reckless imprudence.
• Gonzaga v. People (2015) & Senit v. People (2016) — Cited as cases where the Court, despite finding guilt for reckless imprudence resulting in multiple consequences including damage to property, did not impose a separate fine for damage to property, treating them as complex crimes. The current ruling corrects this by mandating a separate fine.
• People v. Villanueva (1961) & People v. Malabanan (1961) — Cited in the discussion of historical court jurisdiction determination, where the fine for damage to property was considered. The Court noted that BP 129, as amended by RA 7691, changed this, making the fine for damage to property in criminal negligence cases irrelevant for determining jurisdiction between first and second-level courts.

• Revised Penal Code, Article 365 (Imprudence and negligence) — This is the central article defining and penalizing reckless imprudence and its consequences. The Court extensively interpreted its paragraphs, particularly regarding the penalties for resulting physical injuries and damage to property, and affirmed that it punishes a distinct quasi-crime.
• Revised Penal Code, Article 48 (Penalty for complex crimes) — The Court ruled this article is inapplicable to quasi-crimes under Article 365, as reckless imprudence is a distinct offense, not a mode of committing other felonies that can be complexed.
• Revised Penal Code, Article 3 (Definitions - dolo and culpa) — Referenced in De los Santos to argue that felonies can be committed by fault (culpa), thus making Article 48 applicable to negligent acts. The current ruling overturns this application to quasi-crimes.
• Revised Penal Code, Article 9 (Grave felonies, less grave felonies and light felonies) — Used in conjunction with Article 25 to classify slight physical injuries as a light felony.
• Revised Penal Code, Article 25 (Penalties which may be imposed) — Used to determine the classification of penalties (e.g., arresto menor as a light penalty).
• Revised Penal Code, Article 266 (Slight physical injuries and maltreatment) — The Court referred to this to determine that the injuries sustained by the victims (requiring 2-5 days of confinement) constituted slight physical injuries, a light felony.
• Republic Act No. 4136 (Land Transportation and Traffic Code), Section 37 (Overtaking) — The MTCC found petitioner violated this by hastily overtaking without determining if the road was clear.
• Republic Act No. 4136 (Land Transportation and Traffic Code), Section 41 (Restrictions on overtaking and passing) — The Court cited this section, which prohibits driving to the left side of the center line in overtaking unless such left side is clearly visible and free of oncoming traffic. Petitioner violated this.
• Republic Act No. 10951 (Act Adjusting the Amount or the Value of Property and Damage on Which a Penalty is Based) — Petitioner argued against its retroactive application. The CA had applied it. The Supreme Court, in its final penalty determination for slight physical injuries (public censure), relied on the specific provisions of Article 365 rather than directly on R.A. 10951 for that aspect, though R.A. 10951 amended the fine thresholds in Article 365.
• New Civil Code, Article 2185 (Presumption of negligence in motor vehicle mishaps) — Applied because petitioner was violating a traffic regulation (driving on the wrong side of the road) at the time of the accident, leading to a presumption of negligence which he failed to rebut.
• New Civil Code, Article 2224 (Temperate or moderate damages) — The CA and SC awarded temperate damages under this article because pecuniary loss was suffered by the victims and the jeepney owner, but the exact amount could not be proven with certainty.
• Batas Pambansa Blg. 129, Section 32(2) (Jurisdiction of MeTCs, MTCs, etc.), as amended by R.A. No. 7691 — This provision grants first-level courts exclusive original jurisdiction over offenses punishable with imprisonment not exceeding six years and, specifically, over offenses involving damage to property through criminal negligence, irrespective of the fine. This was cited to affirm the MTCC's jurisdiction.
• 1987 Constitution, Article VIII, Section 4(3) (Decisions of the Supreme Court) — Referenced to highlight that a doctrine laid down by the Court en banc or in division may only be modified or reversed by the Court sitting en banc, justifying the current En Banc decision to abandon De los Santos.

• Justice Caguioa — Concurred fully with the ponencia. He stressed that the Court's ruling in Angeles v. Jose, applying paragraph 3 of Article 365 (fine for damage to property) even when reckless imprudence also results in injuries to persons, is sound and best conforms to treating Article 365 as punishing a single quasi-crime where penalties for each consequence are added. He also highlighted the important role of prosecutors in ensuring that only one Information is filed accounting for all consequences of the quasi-crime to prevent abuse of the Ivler doctrine, as demonstrated by the defense tactics in the Ivler case itself.

• Justice Perlas-Bernabe — Concurred with the finding of guilt and the upholding of the Ivler doctrine but dissented on the imposition of an additional penalty of fine for damage to property. She argued that paragraph 3 of Article 365 RPC (regarding the fine for damage to property) applies only when damage to property is the sole result of the reckless imprudence. If other acts (like physical injuries) also result, paragraph 1 of Article 365 should apply to all consequences, and the fine under paragraph 3 should not be imposed. She posited that the lawmakers intended to forego the punishment for damage to property when graver consequences (like physical injuries) are also penalized.