MICHAEL JOHN ROBLES VS. PEOPLE OF THE PHILIPPINES

MICHAEL JOHN ROBLES VS. PEOPLE OF THE PHILIPPINES

G.R. No. 223810

August 02, 2023

FACTS:

The Information reads that on or about the 27th day of July 2009, accused Robles, did then and there willfully, unlawfully and feloniously drive without license an unregistered Suzuki Raiders motorcycle with no plate number along CPG North Avenue comer Benigno Aquino Avenue, Tagbilaran City, in a careless, negligent and imprudent manner, in violation of the traffic rules and regulations and ordinances, without due regard to safety, life and property and without taking the necessary precautions to avoid accident to person or damage to property, thereby causing by such carelessness, negligence and imprudence said Suzuki Raiders motorcycle to hit and bump a Yamaha Crypton motorcycle bearing driven by Ronelo causing damage to the motorcycle death to the latter and less serious physical injuries to the backrider. The MTCC found Robles guilty beyond reasonable doubt of the charge of Reckless Imprudence resulting in Homicide, Less Serious Physical Injuries and Damage to Property under Article 365 of the RPC. The CA denied the appeal.

Hence, this petition.

ISSUE:

Whether Robles is guilty beyond reasonable doubt of Reckless Imprudence resulting in Homicide, Less Serious Physical Injuries, and Damage to Property under Article 365 of the RPC.

RULING:

No. Robles is not guilty of the offense charged. The Court held that the defense version is more credible and deserves more weight and credit.

Reckless imprudence, has the following elements: (1) that the offender does or fails to do an act; (2) that the doing or the failure to do that act is voluntary; (3) that it be done without malice; (4) that material damage results from the reckless imprudence; and (5) that there is inexcusable lack of precaution on the part of the offender, taking into consideration his or her employment or occupation, degree of intelligence, physical condition, and other circumstances regarding persons, time and place.

The Court, held that PO3 Maulas' findings are clear and categorical that Robles did not, in fact, come from Calceta Street. Rather, at the time of the incident, he was driving along CPG Avenue heading north, and was about to turn left to Benigno Aquino Avenue at the intersection when Ronelo attempted to overtake him. PO3 Maulas' account has in its favor the presumption of regularity in the performance of official. The relative positions of the two vehicles at the point of impact and thereafter, as reflected in PO3 Maulas' sketch lead to the conclusion that Ronelo was the one who hit Robles and was, in fact, driving at a much faster speed.

A causal connection between Robles' negligence and the injuries or damages complained of was not proven beyond reasonable doubt. The SC cited cases such as that of Ofracio v. People which instruct that in order to establish a motorist's liability for the negligent operation of a vehicle, it must be shown that there was a direct causal connection between such negligence and the injuries or damages complained of. The SC held that Robles could not be presumed negligent, considering that there is no causal connection that could be reasonably drawn between his violations — lack of driver's license and driving an unregistered vehicle — and the proximate cause of the accident. In this connection, the Court notes that the lower courts failed to consider that Robles was, at the time of the mishap, actually accompanied by a back rider in the person of Lopos, a duly licensed driver.

Robles' conviction may not be sustained based on an alternative set of facts not supported by the prosecution's evidence.  The CA overlooked that under the defense's version of the incident: (1) both parties were approaching the intersection from the same direction, (2) thereafter, Robles signaled his intention to turn left, (3) Ronelo, meanwhile, was speeding in his attempt to overtake Robles, and (4) such attempt on the part of Ronelo to overtake caused the collision. Likewise on record is Dr. de los Santos' testimony finding Ronelo to have been "intoxicated" at the time of this accident. Given these alternative set of facts, it cannot simply be concluded that had Robles been in the correct position on the road, the mishap would not have occurred. These are just speculations.

The SC noted the case of Ladeco vs. Angala where the doctrine of last clear chance was discussed- that where both parties are negligent but the negligent act of one is appreciably later than that of the other, or where it is impossible to determine whose fault or negligence caused the loss, the one who had the last clear opportunity to avoid the loss but failed to do so is chargeable with the loss.

In sum, a motorist's liability for a road accident is not determined simply by who among the parties had the right of way or was in the proper lane. Rather, the same is determined by various factors, which include, among others, the relative distances and respective speeds of the vehicles, or who among the parties had the last clear chance to avoid the accident.

Here, the prosecution, and later the lower courts, proceeded on the theory that Robles came from Calceta Street, and not CPG Avenue. As such, the prosecution did not, at all, present any evidence as to the speed and distance of Robles relative to Ronelo, had Robles come from CPG Avenue, and whether such directly caused, or at least materially contributed to, the injuries or damages complained of. Thus, the CA erred in justifying Robles' conviction based simply on the alternative speculative theory that had Robles been in the correct pos1t10n on the road, the mishap would not have happened. This undoubtedly does not satisfy the core requirement of proof beyond reasonable doubt.