G.R. No. L-10181; March 2, 1915
THE UNITED STATES, plaintiff-appellee, vs. MARIANO CRAME, defendant-appellant.

FACTS:
On the night of February 10, 1914, in Manila, the accused, Mariano Crame, a licensed chauffeur, was driving an automobile along Calle Herran. His vehicle collided with and ran over Private George B. Coombs of the U.S. Army, who was crossing the street. The impact caused Coombs severe head injuries, resulting in permanent mental derangement, memory loss, and incurable imbecility, rendering him unfit for military service. Crame reported the accident to the police and the automobile bureau. He claimed he was driving slowly (about 10 miles per hour), suddenly saw Coombs, swerved to avoid him but failed, and stopped shortly after the collision. The trial court convicted Crame of serious physical injuries through reckless negligence (imprudencia temeraria), citing three grounds: (1) failure to sufficiently reduce speed or stop upon seeing Coombs; (2) failure to sound the horn or give warning; and (3) driving on the wrong side of the street (right of center instead of the left). Crame appealed.

ISSUE:
Whether the accused, Mariano Crame, is guilty of the crime of serious physical injuries through reckless negligence.

RULING:
Yes, the Supreme Court affirmed the conviction. The Court found the trial court’s conclusions more than sustained by the evidence. The accused was negligent in several respects: he did not see the pedestrian in time despite the well-lit street; he failed to sound his horn or give any warning of his approach; he did not apply his brakes or make any effective effort to stop; and he was driving on the wrong side of the road at the time of the collision. The Court rejected the defense’s arguments that the victim suddenly appeared and that driving on the right was justified due to street conditions (e.g., streetcar tracks). The Court held that the rules of the road, including keeping to the left, are rules of negligence meant to ensure safety, and deviations require a correspondingly high degree of care, which Crame failed to exercise. His collective actions constituted reckless negligence, making him criminally liable for the serious injuries inflicted upon George B. Coombs. The judgment of the Court of First Instance was affirmed.