G.R. No. 125066 July 8, 1998
ISABELITA REODICA, petitioner, vs. COURT OF APPEALS, and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

On October 17, 1987, petitioner Isabelita Reodica, while driving a van along Doña Soledad Avenue, Parañaque, Metro Manila, allegedly due to recklessness, hit the car of Norberto Bonsol. The incident resulted in slight physical injuries to Bonsol and property damage amounting to P8,542.00. An Affidavit of Complaint was filed on October 20, 1987. An Information was filed on January 13, 1988, before the Regional Trial Court (RTC) of Makati, charging petitioner with “Reckless Imprudence Resulting in Damage to Property with Slight Physical Injury.” Upon arraignment, petitioner pleaded not guilty. The RTC convicted petitioner of the quasi-offense and sentenced her to six months of arresto mayor and to pay P13,542.00 (P8,542.00 for car repairs and P5,000.00 for medical expenses). The trial court justified the prison term, citing that slight physical injuries through reckless imprudence is punished with arresto mayor in its maximum period, referencing a secondary source. Petitioner appealed to the Court of Appeals (CA), which affirmed the RTC decision. Petitioner’s motion for reconsideration raised new issues regarding the penalty, prescription, and jurisdiction. The CA denied the motion. Hence, this petition.

ISSUE

1. Whether the penalty imposed (arresto mayor) was correct for the crime of reckless imprudence resulting in slight physical injuries.
2. Whether the courts erred in “complexing” the crimes of reckless imprudence resulting in damage to property and slight physical injuries.
3. Whether the offense had prescribed and whether the RTC had jurisdiction over the case.

RULING

1. On the Penalty: The Supreme Court held that the penalty imposed was incorrect. The trial court and the CA erroneously cited People v. Aguilar (mis-cited as People v. Aguiles) from a secondary source, which incorrectly stated the penalty as arresto mayor. The correct penalty for slight physical injuries through reckless imprudence, under Article 365 of the Revised Penal Code, is arresto menor in its maximum period (1 month and 1 day to 6 months). The Office of the Solicitor General agreed with this correction.
2. On Complexing the Crimes: The Supreme Court held that the trial court erred in “complexing” the offenses. Reckless imprudence is a single act, but its consequences give rise to multiple liabilities. Following Lontok v. Gorgonio, when the single act of imprudence results in both damage to property and slight physical injuries (both light felonies), they should not be complexed. Instead, separate informations should be filed for each light felony. Therefore, there were two separate light offenses: (1) reckless imprudence with slight physical injuries, and (2) reckless imprudence with damage to property.
3. On Prescription and Jurisdiction: The Supreme Court held that the offense of slight physical injuries through reckless imprudence, being a light felony punishable by arresto menor, prescribes in two months from the date of the commission of the crime (October 17, 1987). The filing of the information on January 13, 1988, was beyond the two-month prescriptive period, thus the crime had prescribed. Regarding jurisdiction, since both resulting offenses are light felonies, the case falls under the exclusive original jurisdiction of the Metropolitan Trial Court (MeTC), not the RTC. The filing of the information with the RTC did not toll the prescriptive period. The Supreme Court cited Zaldivia v. Reyes, which held that the prescriptive period is not tolled by the filing of a complaint with the wrong court.
DISPOSITIVE PORTION:
The decision of the Court of Appeals is SET ASIDE. Criminal Case No. 33919 is ordered DISMISSED. No pronouncement as to costs.