G.R. No. 223810. August 02, 2023
MICHAEL JOHN ROBLES, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

This case involves a vehicular collision between two motorcycles at the intersection of CPG Avenue, Calceta Street, and Benigno Aquino Avenue in Tagbilaran City in the early hours of July 27, 2009. The Yamaha Crypton motorcycle was driven by Ronelo Solas, with backrider Renilda Dimpel. The Suzuki Raider motorcycle was driven by petitioner Michael John Robles, with backrider Renan Lopas. The collision resulted in the death of Ronelo Solas, less serious physical injuries to Renilda Dimpel, and damage to property.
The prosecution’s version, based on testimonies from Renilda Dimpel and witness Arcadia Bendanillo, was that Robles, driving an unregistered motorcycle with no plate number and without a valid driver’s license, suddenly crossed CPG Avenue from Calceta Street at high speed, hitting Ronelo’s motorcycle which was traveling along CPG Avenue (a through street).
The defense’s version, based on testimonies from Robles, Lopas, and witness Bonifacio Dinampo, supported by the police investigation of PO3 Fabio Maulas, was that Robles was traveling along CPG Avenue and signaled to turn left to Benigno Aquino Avenue. Ronelo, driving at high speed and possibly under the influence of alcohol (per the testimony of Dr. Isagani Jodi de las Santos), attempted to overtake Robles on the left, causing the collision. The police report and sketch indicated both vehicles were traveling north on CPG Avenue, with damage to the left side of Robles’ motorcycle and the right side of Ronelo’s motorcycle.
The Municipal Trial Court in Cities (MTCC) found Robles guilty of Reckless Imprudence resulting in Homicide, Less Serious Physical Injuries and Damage to Property. The MTCC gave credence to the prosecution’s version, noting Robles was driving an unregistered vehicle and only had a student driver’s permit without a licensed driver-instructor, constituting violations of traffic rules from which negligence is presumed. The Regional Trial Court (RTC) affirmed the MTCC’s decision. The Court of Appeals (CA) likewise affirmed the lower courts’ rulings.

ISSUE

The core issue is whether the CA erred in affirming the conviction of petitioner Michael John Robles for Reckless Imprudence resulting in Homicide, Less Serious Physical Injuries and Damage to Property.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the assailed CA Decision and Resolution, and ACQUITTED Michael John Robles.
The Court found that the prosecution failed to prove Robles’ guilt beyond reasonable doubt. The element of negligence or imprudence on Robles’ part was not established. The Court held that the lower courts and the CA erred in giving full credence to the prosecution’s version while disregarding the defense’s evidence, which was corroborated by the police investigator’s report and sketch. The police report, being a public document prepared in the regular performance of duty, carried the presumption of regularity. This report supported the defense’s narrative that both vehicles were on CPG Avenue, with Robles making a left turn and Ronelo attempting to overtake.
The Court ruled that Ronelo, as the overtaking vehicle on a through street, had the responsibility to do so with caution and without interfering with the vehicle being overtaken. By attempting to overtake at an intersection (a prohibited act under traffic rules) and potentially while speeding, Ronelo was the party who failed to exercise due diligence. Robles, who signaled his intention to turn, could not have anticipated Ronelo’s sudden, improper, and dangerous overtaking maneuver. The mere fact that Robles was driving with only a student permit on an unregistered motorcycle does not, by itself, establish that such violation was the proximate cause of the accident. The proximate cause was Ronelo’s improper overtaking at an intersection. Consequently, Robles’ criminal liability was not proven beyond reasonable doubt.