G.R. No. L-37633. January 31, 1975.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELICISIMO MEDROSO, JR., accused-appellant.

FACTS

The Provincial Fiscal of Camarines Sur filed an Information accusing Felicisimo Medroso, Jr. of “Homicide through reckless imprudence.” It was alleged that on May 16, 1971, in Bombon, Camarines Sur, Medroso, without a driver’s license, willfully operated a dump truck in a negligent, careless, and imprudent manner, causing it to bump and kill one Iñigo Andes. The case proceeded to the Court of First Instance.
During trial on July 18, 1972, Medroso, assisted by counsel, pleaded guilty to the charge. The prosecution did not object to his claim of two mitigating circumstances: plea of guilty and voluntary surrender. The trial court, while appreciating these mitigating circumstances, considered driving without a license as an aggravating circumstance. It then convicted Medroso and sentenced him to an indeterminate penalty ranging from two years, four months, and one day as minimum, to six years as maximum of prision correccional, plus damages. Medroso appealed, contesting the penalty.

ISSUE

Whether the trial court erred in not applying Article 64 of the Revised Penal Code to reduce the penalty by one degree, given the presence of two mitigating circumstances and the alleged absence of a valid aggravating circumstance.

RULING

The Supreme Court modified the penalty but upheld the trial court’s discretion, dismissing Medroso’s core argument. The Court clarified that while the penalty for homicide through reckless imprudence under Article 365(6) is prision correccional in its medium and maximum periods (2 years, 4 months, 1 day to 6 years), the rules in Article 64 for lowering penalties based on mitigating and aggravating circumstances do not automatically apply. Paragraph 5 of Article 365 explicitly states that in imposing penalties under this article, “the courts shall exercise their sound discretion without regard to the rules prescribed in Article 64.”
The rationale is that quasi-offenses involve varying degrees of carelessness, and courts require ample discretion to impose fair penalties tailored to the specific circumstances, unbound by the rigid arithmetic of Article 64. Therefore, the trial court was not obligated to reduce the penalty by one degree simply because two mitigating circumstances were present without a countervailing aggravating circumstance. This interpretation was supported by precedent (People vs. Agito). The Court agreed that driving without a license is not a generic aggravating circumstance in the context of Article 365 but noted the trial court’s discretion remained broad.
Applying the Indeterminate Sentence Law, the minimum penalty should be within the range of the penalty next lower, which is arresto mayor maximum to prision correccional minimum (4 months, 1 day to 2 years, 4 months). The trial court’s imposed minimum (2 years, 4 months, 1 day) exceeded this by one day. Consequently, the Supreme Court reduced the minimum by one day to two years and four months. The maximum of six years and the awarded damages were affirmed. The award of exemplary damages was specifically justified as a corrective measure for operating a vehicle without a license.