Title
Ofracio vs. People
Case Decision Date
G.R. No. 221981 Nov 4, 2020
Raul Ofracio acquitted as prosecution failed to prove reckless imprudence in fatal
tricycle collision; last clear chance doctrine inapplicable.
Raul Ofracio is acquitted of reckless imprudence resulting in homicide due to
insufficient evidence.
Jur.ph - Case Digest (G.R. No. 221981)
Direct Answer Model - Expanded
Facts:
The case revolves around Raul Ofracio, the petitioner, who was involved in a vehicular
accident on May 29, 2002, in Bibincahan, Sorsogon City, that resulted in the death of Roy
Ramirez, the respondent, and damage to property. Ofracio was driving a tricycle loaded
with 46 pieces of lumber when he collided with Ramirez's tricycle, which was reportedly
driven in a zigzag manner. The collision caused serious injuries to Ramirez, leading to his
instantaneous death. Following the incident, a complaint was filed against Ofracio for
reckless imprudence resulting in homicide and damage to property. On August 7, 2002,
Ofracio pled not guilty during his arraignment at the Municipal Trial Court in Cities (MTC),
where a warrant for his arrest had been issued after a finding of probable cause.
During the pre-trial conference, the parties reached an agreement regarding essential facts
such as the time and place of the incident and the identity of the involved parties. The
prosecution presented witnesses, including police officer SPO2 Camelo Murillo, who
testified about his observations at the accident scene, and Dr. Larry Garrido, who stated
that Ramirez died from cerebral hemorrhage due to a skull fracture resulting from the
accident. The defense, represented by Ofracio and his passenger Reyden Despuig, claimed
that Ofracio was driving cautiously due to the weight of the lumber and testified that the
collision occurred in Ofracio's lane with Ramirez's tricycle approaching erratically.
Initially found guilty by the MTC and sentenced to an indeterminate penalty, Ofracio
appealed to the Regional Trial Court, which affirmed the lower court's decision, asserting
the applicability of the doctrine of last clear chance. The Court of Appeals upheld the ruling,
prompting Ofracio to elevate the matter to the Supreme Court, arguing errors in the
application of the said doctrine and the factual determination regarding negligence.
Issue:
1. Should Raul Ofracio be held liable for reckless imprudence resulting in homicide
based on the doctrine of last clear chance?
Ruling:
The Supreme Court reversed the decisions of the Regional Trial Court and the Court of
Appeals, granting the petition and acquitting Raul Ofracio for failure of the prosecution to
prove his guilt beyond a reasonable doubt.
Ratio:
The Supreme Court emphasized that the doctrine of last clear chance is inapplicable when
it is established that only one party was negligent. For the doctrine to apply, there must be
mutual negligence where the later negligent act of one party leads to harm that the other
party could have avoided. The Court found that both parties exhibited negligence; however,
Ofracio's negligence did not meet the threshold required for liability under the doctrine
since he could not have reasonably avoided the accident.
Ofracio's initial claim that he could not avoid the accident due to the exceptionally short
distance (4 to 5 meters) between the vehicles was upheld by the Court, which noted that a
tricycle traveling at a normal speed could traverse that distance in mere moments. The
Court scrutinized the lower courts' conclusions, stating that mere observations of the
accident do not suffice to establish the last clear chance if the facts do not support the
claimant's position that Ofracio had time and ability to evade the collision. Furthermore,
the Court took judicial notice of vehicle operation standards, emphasizing that the act of
transporting lumber on a tricycle is common practice, and therefore should not
automatically imply imprudence without shown negligence.
Doctrine:
The Supreme Court underscored that the doctrine of last clear chance cannot be relied
upon when only one party exhibits negligence or where the purported negligence does not
establish a clear opportunity for avoidance. The ruling iterated the critical standards
governing findings of reckless imprudence, asserting that prosecution bears the burden of
proving each and every element of the crime charged beyond reasonable doubt, given the
fundamental presumption of innocence afforded to the accused.
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