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CASE DIGEST · CONSTI I · CRIMINAL LAW I

People vs. Santiago

October 25, 2017October 25, 2017 · LEGIStrata

THE PEOPLE OF THE PHILIPPINES ISLANDS, plaintiff-appellee, vs. GREGORIO SANTIAGO,
defendant-appellant.
G.R. No. 17584 March 8, 1922

Nature of the Action: Appeal from the decision of the trial court

Facts: Defendant was driving his car when he ran over Porfiro Parondo, a 7-year-old boy, which
instantly caused the la er’s death. He was then found guilty of homicide with reckless imprudence, was
sentenced to suffer one year and one day or prision correccional, as well as to pay the costs of the trial.
However, defendant contended that Act No. 2886 is unconstitutional, and therefore, the trial court did
not have jurisdiction over his person and the complaint itself.

Issue: Is Act No. 2886 constitutional?

Ruling: The sentence appealed from is hereby affirmed, the appellant being furthermore sentenced to
the accessory penalties prescribed in article 61 of the Penal Code, and to indemnify the heirs of the
deceased in the sum of P1,000 and to the payment of the costs of both instances.

Ratio Decidendi: Yes. Act No. 2996 is not violative of any constitutional provision, nor does it partake of
the same character as that of the provisions of the constitution; thus, the court did not commit any of the
errors assigned. Furthermore, its main purpose is limited to criminal procedure inasmuch as its intention
is to give to its provisions the effect of law in criminal ma ers.

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43 PHIL 120 G.R. NO. 17584 MARCH 8 1922 PEOPLE VS. SANTIAGO POLICE
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