This opinion seeks to answer your question as to the ramifications and distinctions of the ruling

made by the Supreme Court in the cases of Isabelita Reodica vs. Court of Appeals (G.R. No. 125066, July
8, 1998) and in the more recent case of Jason Ivler vs. Hon. Modesto-San Pedro (G.R. No. 172716,
November 17, 2010).

Synopsis of the case of Isabelita Reodica vs. Court of Appeals

On the evening of 17 October 1987, petitioner Isabelita Reodica was driving a can along Dona
Soledad Avenue, Better Living Subdivision, Paranaque, Metro Manila. Allegedly because of her
recklessness, her van hit the car of complainant Norberto Bonsol. As a result, complainant sustained
injuries, while damage to his car amounted to P8,542.00.

Three days after the incident, or on 20 October 1987, the complainant filed an Affidavit of
Complaint against the petitioner with the Fiscal’s Office.

On 13 January 1988, an information was filed before the Regional Trial Court (RTC) of Makati
charging petitioner with “Reckless Imprudence Resulting in Damage to Property with Slight Physical
Injuries.”

On 31 January 1991, the RTC of Makati rendered a decision convicting petitioner of the “quasi
offense of reckless imprudence, resulting in damage to property with slight physical injuries,” and
sentencing her to suffer imprisonment of six (6) months of arresto mayor, and to pay the complainant the
sum of P13,542.

On appeal to the Court of Appeals (CA), the latter affirmed the trial court’s decision.

Hence, the present appeal.

The appeal thus raises the following issues:

(1) Whether the penalty imposed on petitioner is correct.
(2) Whether the quasi offenses of reckless imprudence resulting in damage to property in the
amount of P8,542.00 and reckless imprudence resulting in slight physical injuries are light felonies.
(3) Whether the rule on complex crimes under Article 48 of the Revised Penal Code applies to the
quasi offenses in question.
(4) Whether the duplicity of the information may be questioned for the first time on appeal.
(5) Whether RTC of Makati had jurisdiction over the offenses in question.
(6) Whether the quasi offenses in question have already prescribed.

The Supreme Court (SC) held in this wise:

(1) The proper penalty. - The SC agreed with both petitioner and the OSG that the penalty of six
months of arresto mayor imposed by the RTC and affirmed by respondent CA is incorrect.
However, it did not subscribe to their submission that the penalty of arresto menor in its
maximum is the proper penalty.
(See Article 365 of the RPC)

Synopsis of the case of Jason Ivler vs. Hon. Modesto-San Pedro

…

In the case of Isabelita Reodica vs. Court of Appeals, the Supreme Court, in explaining the
classification of a Quasi-Offense, stated that if a reckless, imprudent or negligent act results in two or
more grave or less grave felonies, a complex crime is thus committed. However, it raised the exception
enunciated in Lontok vs. Gorgonio (89 SCRA 632) where it declared that where one of the resulting
offenses in criminal negligence constitutes a light felony, then there is no complex crime. Thus, it ruled
that the quasi offense of reckless imprudence resulting in slight physical injuries should have been charged
in a separate information because it is not covered by Article 48 of the Revised Penal Code.
 In the Jason Ivler case, the Supreme Court, speaking through Justice Antonio Carpio, stated that
Article 48 does not apply to acts penalized under Article 365 of the RPC. It explained that reckless
imprudence is a single crime and its consequences on persons and property are material only to determine
the penalty. Once convicted or acquitted of a specific act of reckless imprudence, the accused may not be
prosecuted again for that same act. For the essence of the quasi offense of criminal negligence under
Article 365 of the RPC lies in the execution of an imprudent or negligent act that, if intentionally done,
would be punishable as a felony. The law penalizes thus the negligent or careless act, not the result
thereof. The gravity of the consequence is only taken into account to determine the penalty, it does not
qualify the substance of the offense. And, as the careless act is single, whether the injurious result should
affect one person or several persons, the offense (criminal negligence) remains one and the same, and
cannot be split into different crimes and prosecutions.

The Supreme Court in the latter case finally put an end to the bedeviling question of what
approach to follow when presented with a quasi offense resulting in multiple non-crime damages to
persons and property with varying penalties corresponding to light, less grave, or grave offenses. Prior to
the Ivler ruling, jurisprudence has adopted two approaches: one is by applying Article 48 and “complexing”
one quasi-crime with its multiple consequences unless one consequence amounts to a light felony, in
which case charges were split by grouping, on the one hand, resulting acts amounting to grave or less
grave felonies and filing the charge with the second level courts and, on the other hand, resulting acts
amounting to light felonies and filing the charge with the first level courts. Under this approach, the issue
of double jeopardy will not arise if the “complexing” of acts penalized under Article 365 involves only
resulting acts penalized as grave or less grave felonies because there will be a single prosecution of all the
resulting acts. The issue of double jeopardy