G.R. No. 163351 ; June 21, 2005
ANTONIO V. NUEVA ESPAÑA, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.

FACTS

Petitioner Antonio Nueva España, a bus driver, was charged with reckless imprudence resulting in double homicide after his bus collided with a motorcycle on a curve in Negros Oriental on May 15, 1998, killing the motorcycle driver and his back rider. The prosecution presented two eyewitnesses, Julito Dayuday and Florencio Banico, who testified that the bus swerved from its lane while negotiating the curve, striking the motorcycle. Both witnesses also stated that the petitioner left the scene without assisting the victims. The defense presented police officers and another motorist who claimed the motorcycle overshot its lane while attempting to overtake and hit the bus, which was in its proper lane. The defense also asserted that the petitioner rendered aid.
The trial court convicted the petitioner, finding the prosecution witnesses credible. It imposed an indeterminate penalty and ordered the petitioner to pay substantial damages to the victims’ heirs, including large sums for loss of earning capacity. The Court of Appeals affirmed the conviction but modified the penalty and the awarded damages.

ISSUE

Whether the Court of Appeals erred in affirming the conviction for reckless imprudence and in its modification of the awarded damages.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision. On the criminal liability, the Court upheld the factual findings of the lower courts, emphasizing that the assessment of witness credibility is best undertaken by the trial court. The consistent testimonies of the prosecution eyewitnesses, who had no motive to falsely testify, established that the petitioner failed to exercise the necessary precaution while driving on a curve, constituting reckless imprudence. His flight from the scene further evidenced guilt.
Regarding damages, the Court corrected the trial court’s computation. For loss of earning capacity, the Court applied the settled formula and based the computation on the minimum wage, not the alleged but unsubstantiated high incomes claimed by the victims’ families. Actual damages for funeral expenses were reduced to amounts supported by receipts. Moral and exemplary damages were sustained. The Court also imposed temperate damages for the unproven loss of earning capacity of one victim and for other unsubstantiated expenses. The awards were subject to legal interest. The penalty was properly modified in accordance with the Indeterminate Sentence Law.