Reodica vs.

Court of Appeals Name of Digester:

G.R. No: 125066 Date: July 8, 1998 Ponente: Davide, Jr., J.

Subject / Syllabus Topic: Felonies & Crimes: Culpa and Dolo

Petitioner: Isabelita Reodica Respondent: Court of

Appeals, and People of
the Philippines
Recit Summary:

Facts:
1. [October 17, 1987] petitioner, who was driving a van, hit the car of
complainant Norberto Bonsol. Complainant sustained physical injuries
and his car was damaged.
2. Three days later, complainant filed an affidavit of Complaint against
petitioner with the Fiscal’s Office.
3. [January 13, 1988] information was filed before Makati RTC
charging petitioner with “Reckless Imprudence Resulting in Damage
to Property with Slight Physical Injury.”
4. [January 31, 1991] RTC convicted the petitioner of the quasi offense
of reckless imprudence resulting in damage to property with slight
physical injuries.
5. Petitioner appealed to the CA, which affirmed the appealed decision.
6. After filing a Motion for Reconsideration on several supposed errors
(see holding) and having it denied, we have the petition for review on
certiorari under Rule 45 of the Rules of Court.

Relevant Issue/s: Ruling:

a. Are the quasi-offenses of reckless - Petition granted,
imprudence resulting in damage to CA decision is
property / reckless imprudence resulting set aside as the
in slight physical injuries light felonies? RTC who issued
the affirmed
decision had no
jurisdiction.
- Criminal case is
ordered
dismissed.
Holding:
- Petitioner avers that the courts below should have pronounced that
there were two separate light felonies involved, namely:
(1) reckless imprudence with slight physical injuries; and
(2) reckless imprudence with damage to property, instead of
considering them a complex crime.

- Reckless imprudence resulting in slight physical injuries is punishable

by public censure only. Article 9, paragraph 3, of the Revised Penal
 Code defines light felonies as infractions of law carrying the penalty
of arresto menor or a fine not exceeding P200.00, or both. Since
public censure is classified under Article 25 of the Code as a light
penalty, and is considered under Article 71 of the RPC as a penalty
lower than arresto menor, it follows that the offense of reckless
imprudence resulting in slight physical injuries is a light felony.

On the other hand, reckless imprudence also resulting in damage to

property is, as earlier discussed, penalized with arresto mayor in its
minimum and medium periods. Since arresto mayor is a correctional
penalty under Article 25 of the Revised Penal Code, the quasi offense
in question is a less grave felony - not a light felony as claimed by
petitioner.

Note:
- The issue here in the context of the topic is how culpa (in specific a
wrongful act resulting in imprudence) can result in different effects
and different punishments. The same act of imprudence resulted in a
light felony and also a less grave felony (with different punishments)