G.R. No. L-30269 July 19, 1982
Epitacio Buerano, petitioner, vs. Court of Appeals and People of the Philippines, respondents.

FACTS

Petitioner Epitacio Buerano was the driver of a bus involved in a collision with a bakery delivery panel in Tanay, Rizal, on September 20, 1957. The Chief of Police filed a criminal complaint for “Slight and Serious Physical Injuries through Reckless Imprudence.” After trial, the Municipal Court found Buerano guilty and sentenced him accordingly. He appealed to the Court of First Instance (CFI), which affirmed the conviction with a modified penalty.
Subsequently, the Assistant Provincial Fiscal filed a separate criminal case against Buerano for “Damage to property through reckless imprudence” arising from the same vehicular accident. Buerano moved to quash this second information on the ground of double jeopardy, arguing his prior conviction for physical injuries from the same reckless act barred the second prosecution. The CFI denied his motion, convicted him for damage to property, and the Court of Appeals affirmed.

ISSUE

Whether the subsequent prosecution for damage to property through reckless imprudence, after a prior conviction for physical injuries through reckless imprudence arising from the same incident, constitutes double jeopardy.

RULING

Yes, the subsequent prosecution is barred by double jeopardy. The Supreme Court reversed the Court of Appeals, setting aside the conviction for damage to property. The legal logic hinges on the nature of the quasi-offense of criminal negligence under Article 365 of the Revised Penal Code. The law penalizes the single negligent or imprudent act itself, not the various consequences that flow from it. The gravity of the consequences—whether physical injuries to persons or damage to property—merely determines the applicable penalty but does not multiply the offense.
Since both charges for physical injuries and damage to property were derived from one and the same vehicular accident caused by Buerano’s single alleged act of reckless imprudence, prosecuting him separately for each consequence would place him in double jeopardy for the same offense. The Court abandoned the pre-war precedent (People vs. Estipona) cited by the lower courts and instead applied the controlling doctrine established in People vs. Buan. In Buan, the Court held that a single act of negligence, even if it results in multiple consequences, constitutes only one punishable offense. Therefore, a prior conviction or acquittal for any consequence of that single act bars a subsequent prosecution for another consequence of the same act.