Villareal Vs People

VILLAREAL VS.
PEOPLE
G.R. No. 151258
February 1, 2012
FACTS:
In February 1991, seven freshmen law students (including Leonardo "Lenny" Villa) of the
Ateneo de Manila University School of Law signified their intention to join the Aquila Legis
Juris Fraternity (Aquila Fraternity).
On the night of February 8, 1991, the neophytes were "briefed" and brought to the Almeda
Compound in Caloocan City for the commencement of their initiation. The rites were scheduled
to last for three days.
The neophytes were subjected to traditional forms of Aquilan "initiation rites." These rites
included:
1. Indian Run – which required the neophytes to run a gauntlet of two parallel rows of Aquilans,
each row delivering blows to the neophytes;
2. Bicol Express – which obliged the neophytes to sit on the floor with their backs against the
wall and their legs outstretched while the Aquilans walked, jumped, or ran over their legs;
3. Rounds – in which the neophytes were held at the back of their pants by the "auxiliaries" (the
Aquilans charged with the duty of lending assistance to neophytes during initiation rites), while
the latter were being hit with fist blows on their arms or with knee blows on their thighs by two
Aquilans; and
4. Auxies’ Privilege Round – in which the auxiliaries were given the opportunity to inflict
physical pain on the neophytes.
They survived their first day of initiation.
On the morning of their second day, the neophytes were made to present comic plays, play rough
basketball, and recite the Aquila Fraternity’s principles. Whenever they would give a wrong
answer, they would be hit on their arms or legs. Late in the afternoon, the Aquilans revived the
initiation rites proper and proceeded to torment them physically and psychologically. The
neophytes were subjected to the same manner of hazing that they endured on the first day of
initiation.
After a while, accused alumni fraternity members Fidelito Dizon (Dizon) and Artemio Villareal
(Villareal) demanded that the rites be reopened. The head of initiation rites, Nelson Victorino
(Victorino), initially refused. Upon the insistence of Dizon and Villareal, however, he reopened
the initiation rites. The fraternity members, including Dizon and Villareal, then subjected the
neophytes to "paddling" and to additional rounds of physical pain.
Lenny received several paddle blows. After their last session of physical beatings, Lenny could
no longer walk that he had to be carried to the carport. The initiation for the day was officially
ended. They then slept at the carport.
After an hour of sleep, the neophytes were suddenly roused by Lenny’s shivering and incoherent
mumblings. Initially, Villareal and Dizon dismissed these rumblings, as they thought he was just
overacting. When they realized, though, that Lenny was really feeling cold, some of the Aquilans
started helping him. They removed his clothes and helped him through a sleeping bag to keep
him warm. When his condition worsened, the Aquilans rushed him to the hospital. Lenny was
pronounced dead on arrival.
Consequently, a criminal case for homicide was filed against the 35 Aquilans.
The trial court rendered judgment holding the 26 accused guilty beyond reasonable doubt of the
crime of homicide. The criminal case against the remaining nine accused commenced anew.
The CA set aside the finding of conspiracy by the trial court and modified the criminal liability
of each of the accused according to individual participation. One accused had by then passed
away, so the following Decision applied only to the remaining 25 accused:
1. Nineteen of the accused-appellants were acquitted, as their individual guilt was not
established by proof beyond reasonable doubt.
2. Four of the accused-appellants were found guilty of the crime of slight physical injuries.
3. Two of the accused-appellants – Fidelito Dizon and Artemio Villareal – were found guilty
beyond reasonable doubt of the crime of homicide under Article 249 of the Revised Penal Code.
ISSUES:
1) Whether or not the CA committed grave abuse of discretion, amounting to lack or excess of
jurisdiction, when it set aside the finding of conspiracy by the trial court and adjudicated the
liability of each accused according to individual participation (NO)
2) Whether or not the CA committed grave abuse of discretion when it pronounced Tecson,
Ama, Almeda, and Bantug guilty only of slight physical injuries (YES)
3) Whether or not accused Dizon is guilty of homicide (NO)
HELD:
1) NO. Grave abuse of discretion cannot be attributed to a court simply because it allegedly
misappreciated the facts and the evidence. Mere errors of judgment are correctible by an appeal
or a petition for review under Rule 45 of the Rules of Court, and not by an application for a writ
of certiorari. Pursuant to the rule on double jeopardy, the Court is constrained to deny the
Petition contra Victorino et al. – the 19 acquitted fraternity members.
A verdict of acquittal is immediately final and a re-examination of the merits of such acquittal,
even in the appellate courts, will put the accused in jeopardy for the same offense.
2) YES. The CA committed grave abuse of discretion amounting to lack or excess of

jurisdiction in finding Tecson, Ama, Almeda, and Bantug criminally liable for slight
physical injuries.
Article 4(1) of the Revised Penal Code dictates that the perpetrator shall be liable for the
consequences of an act, even if its result is different from that intended. Thus, once a person
is found to have committed an initial felonious act, such as the unlawful infliction of physical
injuries that results in the death of the victim, courts are required to automatically apply the legal
framework governing the destruction of life. This rule is mandatory, and not subject to
discretion. The accused cannot be held criminally liable for physical injuries when actual death
occurs.
Attributing criminal liability solely to Villareal and Dizon – as if only their acts, in and of
themselves, caused the death of Lenny Villa – is contrary to the CA’s own findings. From proof
that the death of the victim was the cumulative effect of the multiple injuries he suffered, the
only logical conclusion is that criminal responsibility should redound to all those who have been
proven to have directly participated in the infliction of physical injuries on Lenny.
3) NO. The Court cannot sustain the CA in finding the accused Dizon guilty of homicide
under Article 249 of the Revised Penal Code on the basis of the existence of intent to
kill. Animus interficendi cannot and should not be inferred unless there is proof beyond
reasonable doubt of such intent. Instead, the Court adopts and reinstates the finding of the trial
court in part, insofar as it ruled that none of the fraternity members had the specific intent to kill
Lenny Villa.

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VILLAREAL VS.

They survived their first day of initiation.

3) Whether or not accused Dizon is guilty of homicide (NO)

2) YES. The CA committed grave abuse of discretion amounting to lack or excess of

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