Art 16-20
Art 16-20
ISSUES:
Whether or not petitioner’s constitutional right
under the Double Jeopardy Clause bars further
proceedings in Reckless Imprudence Resulting in
Homicide and Damage to Property for the death of
respondent Ponce’s husband.
RULING:
The accused negative constitutional right not to be
"twice put in jeopardy of punishment for the same
offense" protects him from, among others,
post-conviction prosecution for the same offense,
with the prior verdict rendered by a court of
competent jurisdiction upon a valid information
The two charges against petitioner, arising
from the same facts, were prosecuted under the
same provision of the Revised Penal Code, as
amended, namely, Article 365 defining and
penalizing quasi-offenses.
The doctrine that reckless imprudence
under Article 365 is a single quasi-offense by itself
and not merely a means to commit other crimes
such that conviction or acquittal of such
quasi-offense bars subsequent prosecution for the
same quasi-offense, regardless of its various
resulting acts, undergirded this Court’s unbroken
chain of jurisprudence on double jeopardy as
applied to Article 365.
Our ruling today secures for the accused
facing an Article 365 charge a stronger and simpler
protection of their constitutional rights under the
Double Jeopardy Clause. True, they are thereby
denied the beneficent effect of the favorable
sentencing formula under Article 48, but any
disadvantage thus caused is more than
compensated by the certainty of non-prosecution
for quasi-crime effects qualifying as "light offenses"
(or, as here, for the more serious consequence
prosecuted belatedly).