Reodica vs. Court of Appeals

The Court held that a single act of reckless imprudence resulting in a less grave felony and a light felony does not constitute a complex crime under Article 48 of the Revised Penal Code; the light felony must be charged separately. Furthermore, the Court ruled that the penalty for reckless imprudence resulting in slight physical injuries is public censure, as the exception in the sixth paragraph of Article 365 applies when the penalty for the intentional act is equal to or lower than that provided for reckless imprudence.

On 17 October 1987, petitioner Isabelita Reodica drove a van that collided with Norberto Bonsol's car along Doña Soledad Avenue, Parañaque, Metro Manila. Bonsol sustained slight physical injuries, and his car suffered damage amounting to P8,542.00. Three days later, Bonsol filed an affidavit of complaint with the Fiscal's Office. On 13 January 1988, an information was filed before the Regional Trial Court of Makati charging Reodica with "Reckless Imprudence Resulting in Damage to Property with Slight Physical Injury."

• The Incident: On 17 October 1987, petitioner Isabelita Reodica was driving a van that collided with complainant Norberto Bonsol's car. Complainant sustained slight physical injuries requiring medical attendance for less than nine days, and his car sustained damage amounting to P8,542.00.
• The Complaint: On 20 October 1987, complainant filed an affidavit of complaint with the Fiscal's Office.
• The Information: On 13 January 1988, a single information was filed before the RTC of Makati, charging petitioner with "Reckless Imprudence Resulting in Damage to Property with Slight Physical Injury." Petitioner pleaded not guilty.
• The Conviction: On 31 January 1991, the RTC convicted petitioner and sentenced her to six months of arresto mayor and ordered her to pay P13,542.00 (representing car repairs and medical expenses). The trial court relied on a secondary source that misquoted People v. Aguilar as People v. Aguiles and erroneously stated the penalty as arresto mayor.
• The Appeal: Petitioner appealed to the Court of Appeals, which affirmed the RTC decision on 31 January 1996. Petitioner subsequently filed a motion for reconsideration raising new issues regarding the penalty, the improper complexing of offenses, prescription, and jurisdiction, which the Court of Appeals denied on 24 May 1996.

• Petitioner argued that the penalty of arresto mayor was erroneous because People v. Aguilar actually prescribed arresto menor for slight physical injuries through reckless imprudence.
• Petitioner maintained that the offenses of reckless imprudence resulting in damage to property and slight physical injuries are both light felonies that cannot be complexed under Article 48 of the Revised Penal Code, citing Lontok v. Gorgonio and Arcaya v. Teleron.
• Petitioner contended that the light felony of slight physical injuries through reckless imprudence prescribed in two months, and because the information was filed almost three months after the incident, the offense had already prescribed.
• Petitioner asserted that the RTC lacked jurisdiction because the offenses were light felonies covered by the Rule on Summary Procedure, and filing with the fiscal's office did not toll the prescriptive period under Zaldivia v. Reyes.

• The Office of the Solicitor General (OSG) agreed that the penalty should be arresto menor in its maximum period, not arresto mayor.
• The OSG countered that complexing the offenses was proper under Buerano v. Court of Appeals because the law penalizes the single act of reckless imprudence, not the results.
• The OSG argued that the RTC properly took cognizance of the case because it had jurisdiction over the damage to property, which carried a higher penalty.
• The OSG submitted that the prescriptive period was tolled by the filing of the complaint with the fiscal's office three days after the incident, pursuant to People v. Cuaresma and Chico v. Isidro.

• Procedural Issues:
  • Whether the duplicity of the information may be questioned for the first time on appeal.
  • Whether the Regional Trial Court had jurisdiction over the offenses charged.
  • Whether the quasi-offenses had already prescribed.
• Substantive Issues:
  • Whether the penalty of arresto mayor imposed by the trial court is correct.
  • Whether the quasi-offenses of reckless imprudence resulting in damage to property and slight physical injuries are light felonies.
  • Whether the rule on complex crimes under Article 48 of the Revised Penal Code applies to the quasi-offenses in question.

• Procedural:
  • The Court ruled that petitioner waived the right to question the duplicity of the information by failing to raise it in a motion to quash before pleading. Under Section 3, Rule 120 of the Rules of Court, a court may convict an accused of as many offenses as charged and proved if no objection is made before trial.
  • The Court held that the RTC lacked jurisdiction over the offenses. Under Batas Pambansa Blg. 129, the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts had exclusive original jurisdiction over offenses punishable by imprisonment not exceeding four years and two months or a fine of not more than four thousand pesos. Because the imposable penalties for both reckless imprudence resulting in slight physical injuries (public censure) and reckless imprudence resulting in damage to property (arresto mayor minimum and medium periods) fell within these limits, the RTC had no jurisdiction.
  • The Court ruled that the offenses had not prescribed. The filing of the complaint with the fiscal's office three days after the incident tolled the running of the prescriptive period under Article 91 of the Revised Penal Code. The Court distinguished Zaldivia v. Reyes, noting that it involved a municipal ordinance governed by Act No. 3326, which requires the filing of judicial proceedings to toll prescription, whereas offenses under the Revised Penal Code are interrupted by the filing of the complaint with the fiscal's office.
• Substantive:
  • The Court held that the penalty of arresto mayor was incorrect. The proper penalty for reckless imprudence resulting in slight physical injuries is public censure. Because the penalty for intentional slight physical injuries (arresto menor) is equal to or lower than that provided for reckless imprudence (arresto menor maximum), the exception in the sixth paragraph of Article 365 applies, requiring the penalty next lower in degree. For reckless imprudence resulting in damage to property, the proper penalty is arresto mayor in its minimum and medium periods.
  • The Court held that reckless imprudence resulting in slight physical injuries is a light felony because it is punishable by public censure, a penalty lower than arresto menor. Reckless imprudence resulting in damage to property is a less grave felony because it is punishable by arresto mayor.
  • The Court held that Article 48 on complex crimes does not apply. Citing Lontok v. Gorgonio, the Court ruled that if one resulting offense from criminal negligence is a light felony, there is no complex crime. The light felony must be charged separately or may be absorbed by the grave felony.

• Lontok Doctrine on Complex Crimes and Imprudence — When a single act of reckless imprudence results in a grave or less grave felony and a light felony, there is no complex crime under Article 48 of the Revised Penal Code. The resulting offenses must be treated as separate, and the light felony must be charged in a separate information.
• Interruption of Prescriptive Period under Article 91 — The prescriptive period for offenses punished under the Revised Penal Code is interrupted by the filing of the complaint with the fiscal's office. The rule in Zaldivia v. Reyes (requiring filing in court to toll prescription) applies only to violations of special acts and municipal ordinances governed by Act No. 3326, not to offenses under the Revised Penal Code. Prescription is a matter of substantive law; procedural rules cannot diminish, increase, or modify substantive rights.
• Sixth Paragraph of Article 365, RPC Exception — When the penalty provided for the intentional offense is equal to or lower than the penalty prescribed for reckless imprudence under the first two paragraphs of Article 365, the court shall impose the penalty next lower in degree. Thus, for reckless imprudence resulting in slight physical injuries, the penalty is public censure (one degree lower than arresto menor).

• "Applying article 48, it follows that if one offense is light, there is no complex crime. The resulting offenses may be treated as separate or the light felony may be absorbed by the grave felony. Thus, the light felonies of damage to property and slight physical injuries, both resulting from a single act of imprudence, do not constitute a complex crime. They cannot be charged in one information." (Quoting Lontok v. Gorgonio)
• "It must be stressed that prescription in criminal cases is a matter of substantive law. Pursuant to Section 5(5), Article VIII of the Constitution, this Court, in the exercise of its rule-making power, is not allowed to diminish, increase or modify substantive rights. Hence, in case of conflict between the Rule on Summary Procedure promulgated by this Court and the Revised Penal Code, the latter prevails."

• Lontok v. Gorgonio, 89 SCRA 632 (1979) — Followed. Established that where one of the resulting offenses in criminal negligence constitutes a light felony, there is no complex crime, and the light felony should be charged in a separate information.
• Zaldivia v. Reyes, 211 SCRA 277 (1992) — Distinguished. Held inapplicable because it involved a municipal ordinance governed by Act No. 3326, which requires judicial proceedings to toll prescription, unlike Revised Penal Code offenses.
• People v. Cuaresma, 172 SCRA 415 (1989) — Followed. Held that the filing of the complaint with the fiscal's office suspends the running of the statute of limitations for RPC offenses.
• Uy Chin Hua v. Dinglasan, 86 Phil. 617 (1950) — Applied by analogy. Used to resolve the lacuna in jurisdiction over offenses penalized with censure, holding that such offenses fall under the jurisdiction of inferior courts.

• Article 365, Revised Penal Code — Defines the penalties for imprudence and negligence. The Court applied the first paragraph (reckless imprudence resulting in less grave or light felonies) and the sixth paragraph (exception when the penalty for the intentional offense is equal to or lower).
• Article 48, Revised Penal Code — Governs complex crimes. The Court held this inapplicable when a single act of imprudence results in a less grave felony and a light felony.
• Article 91, Revised Penal Code — Governs computation of prescription of offenses. The Court applied the provision that prescription is interrupted by the filing of the complaint or information, even if merely with the fiscal's office.
• Section 32(2), Batas Pambansa Blg. 129 — Defines the jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts in criminal cases. The Court applied this to conclude that the RTC lacked jurisdiction over the offenses charged.

Bellosillo, Vitug, Panganiban, Quisumbing, JJ.