View full case

JASON IVLER Y AGUILAR v. MARIA ROWENA MODESTO- SAN PEDRO

FACTS:

In August 2004, following a vehicular collision, petitioner Jason Ivler was charged with two separate offenses by the Metropolitan Trial Court of Pasig City, Branch 71 (MeTC): (1) Reckless Imprudence Resulting in Slight Physical Injuries (Criminal Case No. 82367) concerning 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 resulting damages to the Ponce’s vehicle. Ivler posted bail for both cases. On September 7, 2004, Ivler pleaded guilty in Criminal Case No. 82367 and received public censure. Subsequently, Ivler sought to quash the Information in Criminal Case No. 82366, arguing that his prior conviction should bar a second prosecution on the grounds of double jeopardy. The MeTC denied the motion to quash, asserting that the offenses did not share the same identity. Ivler then filed a petition for certiorari with the Regional Trial Court of Pasig City, Branch 157 (RTC), seeking the review of the MeTC's refusal to quash the charge. During this time, proceedings in Criminal Case No. 82366 continued; the MeTC issued an order for Ivler’s arrest after he failed to appear at the arraignment, leading to the suspension of the trial pending his arrest. Respondent Ponce moved for dismissal of Ivler's petition in the RTC on the grounds of his loss of standing due to the arrest warrant. The RTC dismissed Ivler's petition on February 2, 2006, basing its decision on Ivler's non-appearance at the MeTC. Ivler sought reconsideration but was unsuccessful, prompting the current petition for review.

ISSUES:

  1. Whether petitioner forfeited his standing to seek relief in S.C.A. 2803 when the MeTC ordered his arrest following his non-appearance at the arraignment in Criminal Case No. 82366.

  2. If in the negative, whether petitioner's constitutional right under the Double Jeopardy Clause bars further proceedings in Criminal Case No. 82366.

RULING:

  1. Petitioner's Non-appearance at the Arraignment in Criminal Case No. 82366 did not Divest him of Standing to Maintain the Petition in S.C.A. 2803.

  2. The protection afforded by the Constitution shielding petitioner from prosecutions placing him in jeopardy of second punishment for the same offense bars further proceedings in Criminal Case No. 82366.

PRINCIPLES:

  • Double Jeopardy Clause Protects an individual from being prosecuted multiple times for the same offense.

  • Reckless Imprudence as a Single Crime Reckless imprudence is treated as a single crime under Article 365 of the Revised Penal Code, with its various consequences relevant only to the determination of the penalty.

  • Jurisdiction Claims that differ in their resulting harm (e.g., slight physical injuries versus homicide) but arise from the same incident cannot be prosecuted separately under the guise of different offenses.

  • Absconding and Standing Non-appearance at pre-arraignment does not automatically result in loss of standing to seek judicial relief, especially in special civil actions for certiorari.

  • Article 48 Inapplicability Article 48 (on complexing crimes) does not apply to quasi-offenses under Article 365, which penalizes the reckless or negligent act irrespective of its results.

  • Coherence in Penal Code When dealing with reckless imprudence, all consequences resulting from the conduct must be prosecuted in a single charge.