In S/Sgt. Cornelio Paman v. People of the Philippines, the Supreme Court affirmed the Court of Appeals’ decision, finding S/Sgt. Cornelio Paman guilty of reckless imprudence resulting in serious physical injuries. The ruling underscores that violating traffic regulations at the time of a vehicular accident presumes negligence, shifting the burden to the driver to prove otherwise. This case highlights the importance of adhering to traffic laws and the legal consequences of failing to do so, particularly when such violations lead to injuries.

When Lanes Cross: Reckless Driving and the Presumption of Negligence

The case revolves around a collision between a motorcycle driven by Ursicio Arambala and a multicab driven by S/Sgt. Cornelio Paman. On October 14, 2004, Arambala was heading towards Southern Mindanao Colleges when Paman’s multicab crossed his path, resulting in a collision. Arambala sustained serious head injuries, leading to the filing of criminal charges against Paman for reckless imprudence resulting in serious physical injuries. The Municipal Trial Court in Cities (MTCC) initially convicted Paman, but the Regional Trial Court (RTC) reversed this decision, acquitting Paman and stating that Arambala was at fault.

The Court of Appeals (CA) then overturned the RTC’s decision, reinstating Paman’s conviction. The CA emphasized that Paman was driving on the wrong side of the road, making him liable for the collision. Paman appealed to the Supreme Court, arguing that the RTC’s acquittal should stand and that he was not negligent. He claimed Arambala should have taken better precautions to avoid the accident. The Supreme Court was tasked with determining whether Paman’s actions constituted reckless imprudence and whether the CA correctly reversed the RTC’s acquittal.

The Supreme Court denied Paman’s petition, affirming the CA’s decision with a modification to the penalty. The Court reiterated the doctrine of finality of acquittal but acknowledged exceptions, including instances where the trial court commits grave abuse of discretion. It cited the case of People v. Sandiganbayan, which states that certiorari is available when a court blatantly abuses its authority to the point of depriving it of the power to dispense justice. Here, the OSG successfully demonstrated that the RTC disregarded evidence indicating Paman was at fault.

The Court emphasized that driving on the wrong side of the road constituted a clear violation of traffic regulations. The Court referenced CA’s observation, stating that Arambala was driving on his rightful lane when Paman’s multicab crossed his path coming from his left side along Broca Street using the wrong lane to cross the said intersection. It underscored that the accident would not have occurred had Paman stayed on his lane, thus highlighting Paman’s fault.

The Supreme Court cited Article 2185 of the Civil Code, which establishes a presumption of negligence if a driver violates traffic regulations at the time of a mishap:

Article 2185. Unless there is proof to the contrary, a person driving a vehicle is presumed negligent if, at the time of the mishap, he was violating any traffic regulation.

This legal principle means that Paman, by driving on the wrong side of the road, was presumed negligent unless he could prove otherwise, which he failed to do. The Court also referred to Section 4l(a) of Republic Act No. 4136, known as the Land Transportation and Traffic Code, which restricts overtaking and passing:

Sec. 41. Restrictions on overtaking and passing. (a) The driver of a vehicle shall not drive to the left side of the center line of a highway in overtaking or passing another vehicle proceeding in the same direction, unless such left side is clearly visible, and is free of oncoming traffic for a sufficient distance ahead to permit such overtaking or passing to be made in safety.

The court emphasized that a driver abandoning his proper lane to overtake must ensure the road is clear and proceed safely. If the passage cannot be made safely, the driver must reduce speed or stop to avoid a collision. Paman’s actions, driving on the wrong side of the road and failing to ensure a safe passage, directly led to the collision and Arambala’s injuries.

In determining the appropriate penalty, the Supreme Court considered Article 365 of the Revised Penal Code (RPC), which addresses imprudence and negligence:

Article 365. Imprudence and negligence. – Any person who, by reckless imprudence, shall commit any act which, had it been intentional, would constitute a grave felony, shall suffer the penalty of arresto mayor in its maximum period to prision correccional in its medium period; if it would have constituted a less grave felony, the penalty of arresto mayor in its minimum and medium periods shall be imposed; if it would have constituted a light felony, the penalty of arresto menor in its maximum period shall be imposed.

The Court noted that the physical injuries suffered by Arambala required medical attendance for more than 30 days, classifying the offense as a less grave felony under Article 263(4) of the RPC. Consequently, the penalty was set to arresto mayor in its minimum and medium periods, or from one month and one day to four months. The Indeterminate Sentence Law did not apply since the maximum term did not exceed one year. The Supreme Court imposed a straight penalty of two months and one day of arresto mayor, considering the absence of mitigating or aggravating circumstances.

The Supreme Court’s decision underscores the importance of adhering to traffic laws and the consequences of failing to do so. The presumption of negligence under Article 2185 of the Civil Code places a significant burden on drivers who violate traffic regulations, emphasizing the need for caution and diligence on the road. The case serves as a reminder that reckless driving can lead to severe legal repercussions, including imprisonment.

FAQs

What was the key issue in this case?	The key issue was whether S/Sgt. Cornelio Paman was liable for reckless imprudence resulting in serious physical injuries due to a traffic collision. The Supreme Court examined if the Court of Appeals correctly reversed the RTC’s acquittal based on Paman’s violation of traffic regulations.
What is the presumption of negligence in traffic accidents?	Under Article 2185 of the Civil Code, a driver violating traffic regulations at the time of an accident is presumed negligent. This means the burden shifts to the driver to prove they were not negligent, reinforcing the importance of following traffic laws.
What traffic regulation did Paman violate?	Paman violated traffic regulations by driving on the wrong side of the road while attempting to overtake another vehicle. This is a violation of Section 4l(a) of Republic Act No. 4136, also known as the Land Transportation and Traffic Code.
What was the ruling of the Supreme Court?	The Supreme Court affirmed the Court of Appeals’ decision, finding Paman guilty of reckless imprudence resulting in serious physical injuries. The Court, however, modified the penalty to a straight term of imprisonment of two (2) months and one (1) day of arresto mayor.
What is the significance of Article 365 of the Revised Penal Code in this case?	Article 365 of the Revised Penal Code addresses the penalties for imprudence and negligence. The Supreme Court used this article to determine the appropriate penalty for Paman’s reckless imprudence.
What does reckless imprudence mean?	Reckless imprudence involves voluntarily doing an unlawful act or omitting to do a lawful act, resulting in material damage due to lack of foresight or skill. It is essentially acting without the necessary caution that a reasonable person would exercise.
Can a judgment of acquittal be appealed?	Generally, a judgment of acquittal is final and unappealable, but there are exceptions. These exceptions include instances where the prosecution is denied due process or when the trial court commits grave abuse of discretion.
What was the basis for the Court of Appeals reversing the RTC decision?	The Court of Appeals reversed the RTC decision because the RTC disregarded evidence showing Paman was driving on the wrong side of the road. This constituted grave abuse of discretion, allowing the CA to overturn the acquittal.

The Paman v. People case reinforces the importance of responsible driving and adherence to traffic laws. The ruling underscores the principle that violating traffic regulations creates a presumption of negligence, with potentially severe legal and personal consequences. It serves as a reminder of the need for caution and diligence while operating vehicles on public roads.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: S/SGT. CORNELIO PAMAN, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT, G.R. No. 210129, July 05, 2017