G.R. No. L-19660 May 24, 1966
THE PEOPLE OF THE PHILIPPINES, plaintiff and appellant, vs. AMBROCIO CANO Y PINEDA, defendant and appellee.

FACTS

On or about August 2, 1961, the Provincial Fiscal of Pampanga filed an information in the Court of First Instance of Pampanga accusing Ambrocio Cano y Pineda of the crime of damage to property with multiple physical injuries through reckless imprudence. The information alleged that on September 21, 1960, Cano, driving a La Mallorca Pambusco bus in a negligent manner, caused it to hit a Philippine Rabbit Bus, resulting in property damage of P5,023.55 and physical injuries to numerous passengers. The injuries described ranged from those requiring medical attendance for not less than three months (serious), to those requiring one week to one month (less serious), to those requiring seven to nine days (slight). Upon arraignment, the defendant pleaded not guilty. Later, he filed a motion to quash the information on three grounds: (1) the crime of slight physical injuries through reckless imprudence had prescribed; (2) the court had no jurisdiction over the crime of slight physical injuries through reckless imprudence; and (3) the crime of slight physical injuries through reckless imprudence cannot be complexed with damage to property, serious and less serious physical injuries through reckless imprudence. The lower court granted the motion, holding that the misdemeanor of slight physical injuries through reckless imprudence could not be validly complexed with grave or less grave felonies. It ordered the prosecution to amend the information by deleting all reference to slight physical injuries. The prosecution’s motion for reconsideration was denied, prompting this appeal.

ISSUE

Whether the lower court erred in granting the motion to quash based on the theory that the offense of slight physical injuries through reckless negligence cannot be complexed with damage to property and serious/less serious physical injuries through reckless imprudence.

RULING

The Supreme Court set aside the order of the lower court and remanded the case for trial on the merits. The Court held that the information did not purport to complex the offense of slight physical injuries with other offenses. It merely alleged that, through a single act of reckless negligence by the defendant, multiple consequences ensued: damage to property and various degrees of physical injuries (serious, less serious, and slight). The Court clarified that criminal negligence is treated as a quasi-offense, where what is principally penalized is the mental attitude or condition behind the act (the “imprudencia punible”), not the consequences per se. The information charged only one quasi-offense of reckless imprudence, with its resulting consequences. Furthermore, the Court ruled that the proper procedure for the lower court was to reserve the resolution of any issues regarding the prescription or complexity of the slight physical injuries until after the trial on the merits, as the court unquestionably had jurisdiction over the charge of damage to property and serious/less serious physical injuries through reckless negligence. Splitting the action into separate informations for different injury degrees would cause unnecessary inconvenience and require the presentation of substantially the same evidence in different courts.