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REYNALDO S. MARIANO v. PEOPLE

FACTS:

Ferdinand de Leon, along with his wife and child, was driving his jeep when Reynaldo Mariano, driving a Toyota pick-up, almost bumped into them. Ferdinand became angry and blocked Reynaldo's path, leading to a brief altercation. They were eventually calmed down by Ferdinand's uncle, Luis de Leon, and parted ways. Instead of going home, Ferdinand decided to visit his mother's house. As he was getting off his jeep, he was struck by Reynaldo's pick-up, which caused him to lose consciousness and suffer multiple facial injuries, a fracture, and subdural hemorrhage. Ferdinand's medical expenses amounted to P66,243.25. Reynaldo was initially convicted of frustrated homicide and sentenced to three years and four months to six years and one day of imprisonment. However, on appeal, the Court of Appeals modified the conviction to reckless imprudence resulting in serious physical injuries, and reduced the penalty to two months and one day to one year, seven months, and eleven days of imprisonment. The Court subsequently affirmed Reynaldo's conviction for reckless imprudence resulting in serious physical injuries.

ISSUES:

  1. Whether or not the petitioner is guilty of reckless imprudence resulting in serious physical injuries.

  2. Whether or not the mitigating circumstance of voluntary surrender can be appreciated in the petitioner's favor.

  3. Whether the penalty imposed by the Court of Appeals is correct.

  4. Whether the award of actual and moral damages is proper.

  5. Whether the penalty imposed on the petitioner is appropriate.

  6. Whether the interest rate on the awarded damages is proper.

RULING:

  1. The Court affirms the findings of the lower courts that the petitioner is guilty of reckless imprudence resulting in serious physical injuries. The Court agrees with the conclusion of the lower courts that the petitioner drove his pick-up truck at a fast speed in order to overtake the jeep of the victim, which resulted in the collision and the victim's injuries.

  2. The Court rules that the mitigating circumstance of voluntary surrender cannot be appreciated in the petitioner's favor. Article 365 of the Revised Penal Code provides that in the imposition of penalties for quasi-offenses, the courts shall exercise their sound discretion without regard to the rules prescribed in Article 64 of the Revised Penal Code. The trial court was not bound to apply paragraph 5 of Article 64 even if the petitioner had two mitigating circumstances in his favor with no aggravating circumstance to offset them.

  3. No, the penalty imposed by the Court of Appeals is incorrect. The act that caused the serious physical injuries, had it been intentional, would be a less grave felony under Article 25 of the Revised Penal Code. Thus, the correct penalty is arresto mayor in its minimum and medium periods, which ranges from one to four months.

  4. Yes, the award of actual and moral damages is proper. Actual damages must be proved with a reasonable degree of certainty and based on the amounts actually expended by the victim. In this case, the receipts presented by the Prosecution proved the expenses actually incurred. However, the moral damages were reduced to P10,000 to reasonably approximate the extent of the hurt caused and the gravity of the wrong done.

  5. The penalty to be imposed on the petitioner is a straight penalty of two months of arresto mayor.

  6. The awards for actual and moral damages shall earn 6% interest rate per annum from the finality of the decision until fully paid.

PRINCIPLES:

  • Reckless imprudence consists of voluntary, but without malice, doing or failing to do an act which results in material damage due to inexcusable lack of precaution. The act must be more than mere negligence and must involve willful and wanton disregard of the consequences.

  • The findings of the trial court, especially when affirmed by the Court of Appeals, are binding and conclusive upon the Supreme Court.

  • The penalty for reckless imprudence is based on the gravity of the resulting injuries had the act been intentional. The penalty prescribed by the law must be imposed on the offender and should not exceed what is allowed.

  • The penalty for serious physical injuries shall be determined based on the consequences of the injuries inflicted.

  • Actual damages must be capable of proof and actually proved with a reasonable degree of certainty.

  • Moral damages are given to ease the victim's grief and suffering and should reasonably approximate the extent of the hurt caused and the gravity of the wrong done.

  • An interest of 6% per annum is imposed on the actual and moral damages from the finality of the decision until full payment, in accordance with Circular No. 799, series of 2013 issued by the Office of the Governor of the Bangko Sentral ng Pilipinas.

  • The penalty to be imposed should be appropriate to the offense committed.

  • The interest rate on awarded damages should be reasonable and in accordance with prevailing jurisprudence.