GR 128474; (October, 2004) (Digest)
G.R. No. 128474 ; October 6, 2004
ARNEL GABRIEL, petitioner, vs. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
The case stems from a fatal three-vehicle collision on Maharlika Highway in San Pablo City on April 19, 1990, involving a jeepney driven by petitioner Arnel Gabriel, a Volkswagen Beetle, and a six-wheeler truck. The collision resulted in three deaths and injuries. The prosecution, through the testimony of truck driver Romeo Macabuhay, alleged that Gabriel’s jeepney, traveling at high speed, veered into the opposite lane after negotiating a curve, colliding with the Beetle and subsequently with the truck. The Regional Trial Court convicted Gabriel of Reckless Imprudence Resulting to Double Homicide and Damage to Property, a decision affirmed with modification by the Court of Appeals.
In his defense, Gabriel claimed he was driving prudently on his correct lane when the Beetle, allegedly attempting to overtake the truck, encroached into his lane and bumped his jeepney, causing it to overturn and be hit by the truck. He presented a passenger and a barangay chairman to corroborate his version. The trial court, however, found the prosecution’s evidence more credible, noting inconsistencies in the defense’s narrative and the improbability of the barangay chairman’s claimed presence not being noted in the police report.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of petitioner Arnel Gabriel for the crime of Reckless Imprudence Resulting to Multiple Homicide, Serious Physical Injuries and Damage to Property.
RULING
The Supreme Court denied the petition and affirmed the conviction. The Court emphasized that factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally binding unless there is a clear showing of error. It found no reason to deviate from this rule, as the lower courts correctly appreciated the evidence. The Court upheld the finding of negligence on Gabriel’s part, applying the doctrine of res ipsa loquitur.
The legal logic is that the circumstances of the accident—a vehicle crossing into the opposite lane on a curve—spoke of negligence attributable to its driver. Gabriel failed to rebut the presumption of negligence. The Court explained that a driver must operate a vehicle with due care, adjusting speed, especially on curves, to maintain control and avoid collisions. By failing to do so, Gabriel’s imprudence was the proximate cause of the accident. The modification of the penalty and the award of damages by the appellate court were also sustained as correct applications of law, including the proper computation of indemnity for loss of earning capacity based on established jurisprudence.