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Jason Ivler Vs San Pedro

This document summarizes a Supreme Court case from 2010 regarding double jeopardy. Jason Ivler was charged with two offenses stemming from a vehicular collision - reckless imprudence resulting in slight injury for one victim, and reckless imprudence resulting in homicide and damage to property for a second victim. Ivler pleaded guilty to the first charge and argued the second charge constituted double jeopardy. The court found reckless imprudence to be a single crime, with consequences on persons and property only determining penalty. As such, prosecuting Ivler for two similar reckless imprudence charges violated double jeopardy protections. The Supreme Court reversed the lower court's dismissal, finding Ivler could not be prosecuted twice for the single crime.

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26 views1 page

Jason Ivler Vs San Pedro

This document summarizes a Supreme Court case from 2010 regarding double jeopardy. Jason Ivler was charged with two offenses stemming from a vehicular collision - reckless imprudence resulting in slight injury for one victim, and reckless imprudence resulting in homicide and damage to property for a second victim. Ivler pleaded guilty to the first charge and argued the second charge constituted double jeopardy. The court found reckless imprudence to be a single crime, with consequences on persons and property only determining penalty. As such, prosecuting Ivler for two similar reckless imprudence charges violated double jeopardy protections. The Supreme Court reversed the lower court's dismissal, finding Ivler could not be prosecuted twice for the single crime.

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martinmanlod
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Jason Ivler vs San Pedro

G.R. No. 172716


November 17, 2010

FACTS:

• Following a vehicular collision in August 2004, petitioner Jason Ivler was charged before the MeTC of Pasig
City, with two separate offenses: (1) Reckless Imprudence Resulting in Slight Physical Injuries for injuries
sustained by respondent Evangeline L. Ponce (respondent Ponce); and (2) Reckless Imprudence Resulting in
Homicide and Damage to Property for the death of respondent Pence’s husband Nestor C. Ponce and
damage to the spouses Ponce’s vehicle. Petitioner posted bail for his temporary release in both cases.
• On September 7, 2004, Ivler pleaded guilty on the first offense and meted public censure as penalty. He
invokes this conviction as a ground in his motion to quash the information for the second offense contending
it places him in double jeopardy for the same offense of reckless imprudence.
• The MeTC refused quashal of the information, finding no identity of offenses in the two cases. Thus
petitioner’s motion for certiorari was elevated before the RTC while moving for the suspension of the
criminal case before the MeTC pending resolution of the prejudicial question as subject of his motion for
reconsideration at the RTC. MeTC however proceeded with the criminal proceeding. The non-appearance
of Ivler to the proceeding resulted to the cancellation of his bail and order of his arrest was issued. Seven
days later, the MeTC issued a resolution denying petitioners motion to suspend proceedings and postponing
his arraignment until after his arrest. Petitioner sought reconsideration but as of the filing of this petition,
the motion remained unresolved.
• Ponce filed a motion to dismiss the motion for certiorari filed by Ivler on the ground that he loss standing to
maintain suit. RTC dismissed said petition on this ground thus this petition to the Supreme Court.

ISSUE:
Whether or not reckless imprudence is a single crime which bars further proceedings on the second
offense. (Constitutional right under Double Jeopardy Clause)

HELD:

Yes. Reckless imprudence is a single crime. Its consequences on persons and property are material only
to determine the penalty.
In this case, the two charges were prosecuted by the court under the provision of Article 365 of the
Revised Penal Code that penalizes quasi-offenses such as negligence. What this provision contemplates in quasi-
offenses of criminal negligence is punishing the act of negligence that if intentionally done will constitute a
criminal offense. Thus, the law punishes the negligent act and not the result thereof. It takes into account the
gravity of the offenses in determining the penalty but not to qualify the substance of the offense. It treats a
negligent act as single whether the injurious result affects one or several persons. The offense of criminal
negligence remains as one and cannot be split into different crimes and prosecutions. The principle of
prosecuting quasi offenses remain intact in the case thus the petitioner cannot be prosecuted for 2 offenses of
similar charges on reckless imprudence. His prosecution on the first offense thus bars another prosecution for
the second offense by virtue of the principle of double jeopardy. Hence, the Supreme Court reversed the
decision of the lower court.

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