The Supreme Court (SC) ruled that courts must apply mitigating and aggravating circumstances in reckless imprudence cases involving motor vehicles, a decision that reduced the sentence of a driver convicted in a fatal road accident.

In a ruling penned by Associate Justice Antonio Kho Jr., the SC En Banc upheld the conviction of Noli Ilon for reckless imprudence resulting in homicide but reduced his prison term after recognizing his voluntary surrender as a mitigating circumstance.

The case stemmed from an accident in which Ilon, while driving his employer’s vehicle near an intersection, struck a trisikad driven by Lee dela Cruz, who later died.

Both the Municipal Trial Court in Cities and the Regional Trial Court found Ilon guilty, ruling that he failed to exercise proper caution by accelerating instead of slowing down near the intersection.

The Court of Appeals affirmed the conviction and increased the penalty, citing his alleged failure to assist the victim.

The SC rejected Ilon’s claim that the victim contributed to the accident, stressing that motorists must drive at reasonable speed, especially near intersections.

However, the tribunal ruled that Ilon’s voluntary surrender should mitigate his sentence and clarified that such cases must follow Article 64 of the Revised Penal Code.