G.R. No. L-6382 March 30, 1954
MANUEL LAPUZ, petitioner, vs. THE COURT OF APPEALS, ET AL., respondents.

FACTS

A collision occurred on February 6, 1950, in Malolos, Bulacan, between Philippine Rabbit Bus No. 43 and Westlutran Bus No. 62, driven by Manuel Lapuz. This incident led to two criminal cases filed against Lapuz in the Court of First Instance of Bulacan. In the first case, he was charged with homicide with serious physical injuries through reckless imprudence for the death of Pedro Simbillo and injuries to Remigio Barnes and Marcelino Cardenas, passengers of the Philippine Rabbit bus. In the second case, he was charged with damage to property through reckless imprudence for the destruction of the Philippine Rabbit bus. The trial court convicted Lapuz in both cases, imposing imprisonment, indemnities, and a fine. The Court of Appeals affirmed the judgment in toto. Lapuz appealed to the Supreme Court via certiorari, arguing, among other points, that his single negligent act should constitute only one complex crime under Article 48 of the Revised Penal Code.

ISSUE

Whether the petitioner should be convicted of a single complex crime for his single negligent act resulting in death, serious physical injuries, and damage to property, rather than separate convictions under different laws.

RULING

The Supreme Court modified the appealed judgment. It held that while the separate convictions by the lower courts were initially proper under the applicable laws at the time of the accident (Section 67(d) of the Revised Motor Vehicle Law for the homicide and injuries, and Article 365 of the Revised Penal Code for the damage to property), Republic Act No. 587, which took effect later but is more favorable to the petitioner, amended the Motor Vehicle Law. Under this amendatory law, such cases are to be punished under the provisions of the Penal Code. Applying this favorable law, the petitioner’s single act of negligence constituted the complex crime of homicide with serious physical injuries and damage to property through reckless imprudence under Article 365 of the Revised Penal Code, as provided in Article 48. Consequently, the petitioner was sentenced to an indeterminate penalty of 4 months of arresto mayor to 2 years and 4 months of prision correccional, and ordered to indemnify the heirs of Pedro Simbillo (P4,000), Remigio Barnes (P600), and Florencio P. Buan (P6,676.88), with subsidiary imprisonment in case of insolvency, plus costs.