By Atty. Julius Gregory B. Delgado
“MICHAEL JOHN ROBLES VS. PEOPLE OF THE PHILIPPINES”, G.R. NO. 223810 (AUGUST 2, 2023): BOHOL
CASE ENRICHES JURISPRUDENCE ON APPRECIATION OF EVIDENCE IN TRAFFIC COLLISION INCIDENT
The case stems from a vehicular collision incident between a Yamaha Crypton motorcycle driven
by the late Ronelo Solas and a Suzuki Raider motorcycle driven by petitioner Michael John Robles. Petitioner Robles had only a Student Driver’s Permit, but he was accompanied by a person with a Driver’s License, Mr. Renan Lopos. Mr. Solas, who died because of the incident, was accompanied by Ms. Renilda Dimpel. The Suzuki Raider driven by petitioner Robles was unregistered. Because of the death of Mr. Solas and injuries of Ms. Dimpel, a criminal case for Reckless Imprudence resulting in Homicide, Less Serious Physical Injuries and Damage to Property under Article 365 was filed.
The version of the prosecution is that they were supposedly traversing CPG Avenue North when
petitioner (accused therein) Robles, allegedly in a reckless and speeding manner who was traversing and coming from Calceta St. towards Benigno Aquino, Jr. Avenue (Old Airport Road), bumped and hit the Yamaha Crypton motorcycle of Mr. Solas and Ms. Dimpel causing them to be thrown away. The version
of the defense is that the Suzuki Raider was traversing CPG Avenue North when they were about to turn
left to Benigno Aquino, Jr. Avenue (Old Airport Road) when the Yamaha Crypton driven by Mr. Solas tried to overtake them at the left causing the collision of the two motor vehicles. The Municipal Trial Court in Cities of Tagbilaran City convicted petitioner (accused therein) Robles which was affirmed by the Regional Trial Court of Tagbilaran City. The Court of Appeals affirmed the rulings of the MTCC and RTC, hence, the recourse to the Supreme Court on Petition for Review on Certiorari.
The Supreme Court reversed the rulings of the MTCC, RTC and the CA and held that while
factual findings of the trial court are accorded great weight and respect especially when they are affirmed by the appellate court, there are exceptions and one of these exceptions is that, “where the trial court overlooked, misunderstood or misapplied some facts or circumstances of weight and substance which can affect the result of the case.” The Supreme Court heavily relied on the testimony of Police Officer 3 Fabio Maulas who conducted the investigation, submitted a sketch which was reproduced by the Supreme Court in its Decision, and who testified categorically that it is the version of petitioner Robles which is more credible and believable based on the physical or object evidence. The Court held: First, P03 Maulas’ findings, which were reflected in his police report and sketch,
and which he thereafter repeated in open court, are clear and categorical that Robles did not, in fact, come from Calceta Street. Rather, at the time of the incident, he was driving along CPG Avenue heading north, and was about to turn left to Benigno Aquino Avenue at the intersection when Ronelo attempted to overtake him.
In P03 Maulas’ police report, which he prepared immediately after the incident, and which was
duly recorded in the traffic blotter of the Philippine National Police, Tagbilaran City Police Station, he reported that:
P03 Maulas’ police report and sketch also indicated that Robles’ Suzuki Raider motorcycle
sustained damages on its left side while Ronelo’s Yamaha Crypton sustained damages on its right side.
He testified on this point that:
Notably, such findings are likewise reflected in the photographs of Robles’ Suzuki
Raider motorcycle taken after the incident, which indicate that the motorcycle sustained
damages only on its left side, particularly on the change pedal and driver’s left footrest.
More importantly, on cross examination, P03 Maulas was unwavering that despite
interviewing both Renilda and Robles, he found Robles’ account to be more consistent with
his factual findings, while Renilda’s account was, in his view, improbable. Thus:
It bears stressing that P03 Maulas did not simply wrest his findings out of thin air. As
testified by him, said findings were based on his interviews with various bystanders and
witnesses, on the damages actually sustained by the two motorcycles, and on his own
independent assessment of the relative positions of the vehicles when he arrived at the
scene of the accident. Ultimately, based on the totality of such evidence, PO3 Maulas
categorically concluded that Renilda’s version is “very far from the truth,” “very remote,”
and, in fact, “impossible”. Indeed, the damages sustained by the two motorcycles, as well as
the relative positions of the motorcycles, as observed by P03 Maulas and inferred from said
damages, constitute real evidence that ranks higher in the hierarchy of evidence compared
to testimonial evidence. It is well-settled that object or physical evidence, when offered in
accordance with the requisites for its admissibility, becomes evidence of the highest order
and speaks more eloquently than witnesses put together. It has been characterized as “that
mute but eloquent manifestations of truth which rate high in our hierarchy of trustworthy
evidence,” such that “where the physical evidence on record runs counter to the testimonial
evidence of the prosecution witnesses, xxx the physical evidence should prevail.” Thus, in
People v. Vasquez, this Court refused to lend credence to the incriminating assertions of
prosecution witnesses as to an alleged mauling, and stated that “[t]his Court cannot be
persuaded by the prosecution’s claim of perpetration of physical violence in the absence of
any marked physical injuries on the various parts of the victim’s face and body.”
Also, the Supreme Court held that P03 Maulas’ account has in its favor the presumption of
regularity in the performance of official functions, which presumption the prosecution utterly failed to overturn. The Court held that “Here, the prosecution failed to adduce any evidence to show any
deficiency or irregularity on the part of P03 Maulas in the performance of his official duty as the traffic investigator of the accident. Also, the prosecution did not show that he was impelled by any ill motive or bias to testify falsely. As such, P03 Maulas’ investigation report has in its favor the presumption that official duty had regularly been performed, and thus entitled to weight and respect.” Finally, on the application of Article 2185 of the Civil Code which provides that “Unless there is proof to the contrary, it is presumed that a person driving a motor vehicle has been negligent if at the time of the mishap, he was violating any traffic regulation”, the Court held that there must be a causal connection between the violation of law and the proximate cause of the accident. The Court held: “From
the foregoing premises, it thus cannot be said that Robles could be presumed negligent, considering that there is no causal connection that could be reasonably drawn between his violations – lack of driver’s license and driving an unregistered vehicle – and the proximate cause of the accident. Additionally, there is also no evidence that the violations even contributed to the accident. In this connection, the Court notes that the lower courts failed to consider that Robles was, at the time of the mishap, actually accompanied by a back rider in the person of Lopos, a duly licensed driver.”
The fact that Robles only had a student driver’s permit could not at the onset give rise to a
presumption that he was negligent, hence, he was acquitted. There was an information relayed to this
representation by the counsel of both sides, however, that the parties already entered a settlement during the pendency of the appeals. Nonetheless, this case which happened in Bohol enriched our jurisprudence.