FACTS:

Xerxes Adzuara was convicted by the trial court for reckless imprudence resulting in damage to property with less serious physical injuries. His conviction was affirmed by the Court of Appeals. The incident occurred when Xerxes, then a law student, and his friends were driving along Quezon Avenue. Their car collided with another car owned and driven by Gregorio Martinez, who was executing a U-turn at the time. The collision caused the Martinez's car to be flung 20 meters southward and the Galant to skid southward on the avenue. Both Xerxes and Martinez claimed that they had green traffic lights. Sahlee Martinez, who was seated in the car with her father, sustained injuries and had to be confined at a hospital for five days. Xerxes was charged with reckless imprudence and was eventually convicted by the trial court. The Court of Appeals affirmed the conviction, and Xerxes filed a petition for review on certiorari, arguing that there were no factual circumstances warranting a finding of negligence and that the medical certificate submitted was not enough evidence of the injuries. The Supreme Court found no merit in the petition and upheld the conviction, citing evidence demonstrating Xerxes' negligence and consistent testimony regarding the traffic light.

ISSUES:

1. Whether there are factual circumstances warranting a finding of negligence on the part of petitioner.

2. Whether the medical certificate, unsubstantiated by the doctor's testimony, creates doubt as to the existence of the injuries complained of.

RULING:

1. The Supreme Court finds that there are factual circumstances warranting a finding of negligence on the part of the petitioner. The defense version cannot prevail against the prosecution version, which convincingly demonstrates that the accident occurred because petitioner disregarded the red light and was driving at a fast speed. The consistency of the complainant's testimony regarding the crucial material circumstances of the accident further supports the veracity of the prosecution's version.

2. The medical certificate, even if unsubstantiated by the doctor's testimony, is not enough to create doubt as to the existence of the injuries complained of. The declarations of the complainant and the physical evidence of the damage to his car further confirm the injuries sustained as a result of the collision.

PRINCIPLES:

• Reckless imprudence resulting in damage to property with less serious physical injuries requires a finding of negligence based on factual circumstances. The defense version must be outweighed by the prosecution's version that demonstrates the negligence of the accused.

• Substantial consistency of the complainant's testimony regarding crucial material circumstances surrounding the accident strengthens the veracity of the prosecution's version.

• Even if unsubstantiated by the doctor's testimony, a medical certificate can be considered as evidence of the injuries sustained, especially when supported by the complainant's testimony and physical evidence.