G.R. No. L-3686; January 31, 1952
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AUSPICIO ROMUALDO, defendant-appellant.

FACTS

On April 14, 1947, a passenger truck driven by Auspicio Romualdo ran into a tree due to reckless driving, injuring several passengers. Two injured passengers, Sergia Blaza and Anatecla Abaya, filed a complaint for serious physical injuries in the justice of the peace court. After preliminary investigation, the case was elevated to the Court of First Instance but was ordered returned to the justice of the peace court. The complaint was amended to charge less serious physical injuries through reckless imprudence. This case was tried jointly with another case filed by injured passenger Joaquin Julian for the same offense. The justice of the peace court convicted Romualdo in both cases, sentencing him to 1 month and 1 day imprisonment. The accused appealed to the Court of First Instance, where the cases were docketed as Criminal Cases Nos. 545 and 546.
Meanwhile, two other cases for physical injuries through reckless imprudence were filed by other injured passengers, Artemio Agustin and Remedios Valencia, in the same justice of the peace court and later forwarded to the Court of First Instance, docketed as Criminal Cases Nos. 506 and 538. To consolidate all cases, the provincial fiscal moved for the dismissal of Cases Nos. 545 and 546, and upon dismissal, filed an amended information merging those cases with the others. When the consolidated case was called for hearing, the accused moved to quash, arguing that the dismissal of the appealed cases without his knowledge or consent constituted double jeopardy. The motion was denied, trial proceeded, and Romualdo was found guilty and sentenced to four months’ imprisonment, with indemnity to Joaquin Julian. The accused appealed.

ISSUE

Whether the justice of the peace court had jurisdiction to try and decide the two cases (Criminal Cases Nos. 545 and 546) that were appealed to the Court of First Instance, and consequently, whether the filing of a new information after their dismissal exposed the accused to double jeopardy.

RULING

The Supreme Court affirmed the judgment of the lower court. The justice of the peace court lacked jurisdiction over the two cases because the offense charged, arising from reckless driving resulting in bodily injury, fell under Section 67(d) of the Revised Motor Vehicle Law, not under the Revised Penal Code. The Court held that Section 67(d) of the Revised Motor Vehicle Law, which prescribes a penalty of 15 days to 6 years imprisonment for accidents resulting in death or serious bodily injury due to negligence or reckless driving, superseded Article 365 of the Revised Penal Code for such motor vehicle offenses. The phrase “serious bodily injury” in the Motor Vehicle Law is not synonymous with “serious physical injuries” in the Penal Code; it distinguishes serious from trivial injuries, and its minimum penalty of 15 days is lower than that for less serious physical injuries under the Penal Code. Therefore, the conviction by the justice of the peace court was a nullity, and the proceedings could only be given the effect of a preliminary investigation. The elevation of the cases to the Court of First Instance was not a valid appeal. Thus, the filing of a new information after dismissal did not constitute double jeopardy. The Court also noted that the amendment of the Motor Vehicle Law by Republic Act No. 587 , which made such infractions punishable under the Penal Code, did not affect jurisdiction, as jurisdiction is determined by the law in force at the time of instituting the action.