G.R. No. L-2621. February 28, 1950.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JESUS GUANCO, defendant-appellant.

FACTS

The accused, Jesus Guanco, was convicted by the Justice of the Peace Court of Hinigaran, Negros Occidental, for violating the Motor Vehicle Law ( Act No. 3992 ) by driving a jeep without a license, as he was under 18 years old. He appealed to the Court of First Instance, which also found him guilty and imposed a fine. He then appealed to the Supreme Court, arguing double jeopardy. The record shows that on June 30, 1946, Guanco drove a jeep at an excessive speed, causing it to overturn and kill four passengers. In a separate case, he had already been convicted of multiple homicide through reckless imprudence for the same incident, and his sentence was affirmed by the Court of Appeals.

ISSUE

Whether the conviction for driving without a license under the Motor Vehicle Law places the accused in double jeopardy after he had already been convicted of multiple homicide through reckless imprudence arising from the same incident.

RULING

No. The Supreme Court affirmed the conviction. The offense of driving without a license under Section 27 of the Motor Vehicle Law is distinct and separate from the offense of multiple homicide through reckless imprudence. The two charges involve different elements and laws. Furthermore, Section 68 of the Motor Vehicle Law explicitly provides that conviction for one offense under the Act does not bar prosecution for other offenses committed concurrently. Therefore, the plea of double jeopardy is without merit.

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