People of the Philippines vs. Jose Buan

The essence of the quasi-offense of criminal negligence under Article 365 of the Revised Penal Code lies in the execution of a single imprudent or negligent act, not in the resulting harm; therefore, once an accused is acquitted or convicted of a specific act of reckless imprudence, he may not be prosecuted again for that same act, regardless of the number or gravity of the resulting injuries or damages.

The accused, Jose Buan, was a bus driver for the La Mallorca Company. The case concerns the legal principle of double jeopardy as applied to quasi-offenses under Article 365 of the Revised Penal Code. The doctrine holds that criminal negligence is a single offense, and its various injurious results cannot be split into separate crimes and prosecutions, a principle consistently upheld in both Spanish and Philippine jurisprudence.

On July 23, 1962, Jose Buan was driving a passenger bus of the La Mallorca Company along the MacArthur Highway in Guiguinto, Bulacan. Allegedly due to his negligence and recklessness, the bus struck and collided with a passenger jeep owned by Sergio Lumidao. The collision damaged the jeep, causing it to turn turtle, and injured its passengers. Six passengers suffered slight physical injuries requiring medical attendance for 5 to 9 days, while three others suffered serious bodily injuries needing medical attention for 30 to 45 days. The jeep itself was damaged to the extent of P1,395.00.

A charge for slight physical injuries through reckless imprudence was filed against Buan in the Justice of the Peace Court of Guiguinto, for which he was tried and acquitted on December 16, 1963. Prior to this acquittal, however, the Provincial Fiscal of Bulacan had already filed an information in the Court of First Instance charging Buan with serious physical injuries and damage to property through reckless imprudence. Both charges admittedly referred to the same highway collision.

When arraigned in the Court of First Instance, Buan's counsel moved to quash the charges on the ground that he had already been acquitted of the same offense by the Justice of the Peace Court. The prosecution opposed the motion, and the Court of First Instance denied it. After a motion for reconsideration was denied, the accused appealed directly to the Supreme Court.

• Double Jeopardy: The accused-appellant argued that the second case placed him twice in jeopardy for the same offense and was barred by his previous acquittal by the Justice of the Peace Court of Guiguinto.

• Complexing of Offenses: The Solicitor General argued that the charge for slight physical injuries through reckless imprudence could not be joined with the accusation for serious physical injuries through reckless imprudence because Article 48 of the Revised Penal Code allows only the complexing of grave or less grave felonies.

• Double Jeopardy: Whether the second prosecution for serious physical injuries and damage to property through reckless imprudence placed the appellant twice in jeopardy for the same offense, and is barred by his previous acquittal for slight physical injuries through reckless imprudence arising from the same act.

• Double Jeopardy: Yes. The second prosecution was barred by the previous acquittal. The essence of the quasi-offense of criminal negligence under Article 365 of the Revised Penal Code lies in the execution of a single imprudent or negligent act, not the result thereof, and the offense remains one and the same regardless of the number of injurious results.

• Double Jeopardy: The Court reasoned that once an accused is convicted or acquitted of a specific act of reckless imprudence, he may not be prosecuted again for that same act. The law penalizes the negligent or careless act, not the result. The gravity of the consequence is only considered to determine the penalty and does not qualify the substance of the offense. Because the careless act is single, the offense of criminal negligence remains one and the same, whether the injurious result affects one person or several persons, and cannot be split into different crimes and prosecutions. The Court cited its recent decisions in People vs. Silva, People vs. Diaz, People vs. Belga, and Yap vs. Lutero as constant rulings on the matter. The Court also rejected the Solicitor General's argument based on Article 48, noting that this same argument was considered and rejected in People vs. Diaz, where it was held that the prosecution, having first prosecuted the defendant for the lesser offense, was not in a position to press a more serious charge arising from the same alleged reckless imprudence of which the defendant had been previously cleared.

• Single Offense of Criminal Negligence — The essence of the quasi-offense of criminal negligence under Article 365 of the Revised Penal Code lies in the execution of an imprudent or negligent act, not the result thereof. The law penalizes the negligent or careless act, and since the careless act is single, the offense remains one and the same, regardless of the number of injurious results. The gravity of the consequence only determines the penalty and does not qualify the substance of the offense. The Court applied this doctrine to hold that an acquittal for one injurious result of a single negligent act bars prosecution for other injurious results of the same act.

• "For the essence of the quasi offense of criminal negligence under article 365 of the Revised Penal Code lies in the execution of an imprudent or negligent act that, if intentionally done, would be punishable as a felony. 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." — This passage articulates the core ratio decidendi of the case, defining the nature of criminal negligence as a single offense based on the act, not its consequences, and is the canonical formulation of the doctrine.
• "Reason and precedent both coincide in that once convicted or acquitted of a specific act of reckless imprudence, the accused may not be prosecuted again for that same act." — This statement establishes the direct application of the double jeopardy principle to quasi-offenses, forming the basis for the Court's ruling.

• People vs. Silva, L-15974, January 30, 1962 — Controlling precedent. The Court ruled that an acquittal on a charge of slight physical injuries through reckless imprudence was a bar to another prosecution for homicide through reckless imprudence, where the same vehicular accident resulted in one death, two serious injuries, and three slight injuries.
• People vs. Diaz, L-6518, March 30, 1954 — Controlling precedent. The Court ruled that the dismissal by the Municipal Court of a charge of reckless driving barred a second information for damage to property through reckless imprudence based on the same negligent act. This case also rejected the argument that Article 48 of the Revised Penal Code prevented the joinder of the offenses.
• People vs. Belga, 100 Phil. 996 — Controlling precedent. The dismissal of an information for physical injuries through needless imprudence was declared to block two other prosecutions, one for damage to property through reckless imprudence and another for multiple physical injuries arising from the same collision.
• Yap vs. Lutero, et al., L-12669, April 30, 1959 — Controlling precedent. The Court reasserted the same doctrine that a single act of criminal negligence cannot be split into different crimes and prosecutions.

• Article 365, Revised Penal Code — The provision defining quasi-offenses. The Court applied it to hold that the essence of criminal negligence lies in the single imprudent or negligent act, not in the resulting harm, and that the offense cannot be split into different crimes and prosecutions.
• Article 48, Revised Penal Code — The provision on complex crimes. The Court rejected the Solicitor General's argument that this provision prevented the joinder of the charges, noting that the prosecution was not obliged to first prosecute the lesser offense and, having done so, could not press a more serious charge arising from the same act.

Dizon, Makalintal, Bengzon, J.P., Zaldivar, Sanchez, Angeles, and Fernando, JJ., concurred. Castro, J., took no part.