DOUBLE JEOPARDY: PRIOR CONVICTION OR ACQUITTAL OF RECKLESS IMPRUDENCE BARS SUBSEQUENT PROSECUTION FOR THE SAME QUASI-OFFENSE REGARDLESS OF ITS VARIOUS RESULTING ACTS:

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. x x x x Hence, the Supreme Court finds merit in petitioner’s submission that the lower courts erred in refusing to extend in his favor the mantle of protection afforded by the Double Jeopardy Clause. A more fitting jurisprudence could not be tailored to petitioner’s case than People v. Silva, No. L-15974, 30 January 1962, 4 SCRA 95, a Diaz progeny. There, the accused, who was also involved in a vehicular collision, was charged in two separate Informations with "Slight Physical Injuries thru Reckless Imprudence" and "Homicide with Serious Physical Injuries thru Reckless Imprudence." Following his acquittal of the former, the accused sought the quashal of the latter, invoking the Double Jeopardy Clause. The trial court initially denied relief, but, on reconsideration, found merit in the accused’s claim and dismissed the second case. x x x x (JASON IVLER y AGUILAR vs. HON. MARIA ROWENA MODESTO-SAN PEDRO, G.R. No. 172716, November 17, 2010, CARPIO, J.).