G.R. No. L-19648 February 28, 1966
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. PEDRO MACABUHAY, defendant-appellee.

FACTS

An amended complaint was filed in the Justice of the Peace Court of Rizal, Laguna, charging Pedro Macabuhay with serious physical injuries, less serious physical injuries, double slight physical injuries, and damage to property through reckless imprudence (Criminal Case No. 98). Upon motion of the accused, the charge for slight physical injuries was excluded, and the complaint was re-amended to charge only serious physical injuries, less serious physical injuries, and damage to property through reckless imprudence. Separately, two complaints for slight physical injuries through reckless imprudence arising from the same vehicular incident were filed against Macabuhay in the same court (Criminal Cases Nos. 107 and 108). After trial, the Justice of the Peace Court acquitted Macabuhay in these two cases for slight physical injuries. Following a preliminary investigation in Criminal Case No. 98, an information based thereon was filed in the Court of First Instance of Laguna (Criminal Case No. SP-549), charging Macabuhay with serious physical injuries, less serious physical injuries, and damage to property through reckless imprudence. The Court of First Instance quashed this information on the ground of double jeopardy. The State appeals, seeking modification of the order to allow prosecution for damage to property through reckless imprudence.

ISSUE

Whether the acquittal of the accused in the two cases for slight physical injuries through reckless imprudence bars his subsequent prosecution for damage to property through reckless imprudence arising from the same incident, on the ground of double jeopardy.

RULING

Yes. The Supreme Court affirmed the order quashing the information. The crime of slight physical injuries through reckless imprudence, as charged in the Justice of the Peace Court, necessarily includes the crime of damage to property through reckless imprudence. Applying Section 9, Rule 117 of the Revised Rules of Court on double jeopardy, the Court found that the essential elements of the crime of damage to property through reckless imprudence (the date and place of collision, the accused’s reckless imprudence in driving, and the causing of the bus to hit the jeepney) were all alleged in the complaints for slight physical injuries through reckless imprudence. The complaints also contained an allegation that the accused failed to take necessary precautions to prevent accident to persons and damage to property. Therefore, the offense of damage to property through reckless imprudence is necessarily included in the offense of slight physical injuries through reckless imprudence for which the accused was already acquitted. The Court distinguished the case from People vs. Estipona, noting that in Estipona, the information for damage to property did not describe the offense of physical injuries, whereas here, the complaints for slight physical injuries contained allegations constituting the offense of damage to property. Consequently, the acquittal in the prior cases bars the subsequent prosecution for damage to property through reckless imprudence.