Villareal Vs People

Artemio Villareal vs.
People of the Philippines

Feb. 1, 2012 Gr. No. 121258
Facts
In February 1991, seven freshmen law students of the Ateneo de Manila University School
of Law were subjected to traditional forms of Aquilan “initiation rites” which lasted for
three days. They were tormented physically and psychologically.
Accused non-resident or alumni fraternity members FidelitoDizon and ArtemioVillareal

demanded that the rites be reopened. The head of initiation rites, Nelson Victorino, initially
refused but 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, one of which was so strong it sent him
sprawling to the ground. The neophytes heard him complaining of intense pain and
difficulty in breathing. After their last session of physical beatings, Lenny could no longer
walk.
After an hour of sleep, the neophytes were suddenly roused by Lenny’s shivering and
incoherent mumblings. When his condition worsened, the Aquilans rushed him to the
hospital. Lenny was pronounced dead on arrival.
The trial court rendered judgment holding the 26 accused guilty beyond reasonable doubt
of the crime of homicide, penalized with reclusion temporal under Article 249 of the
Revised Penal Code.
The CA in set aside the finding of conspiracy by the trial court and modified the criminal
liability of each of the accused according to individual participation. Nineteen of the
accused-appellants were acquitted, as their individual guilt was not established by proof
beyond reasonable doubt. Four of the accused-appellants – Vincent Tecson, Junel Anthony
Ama, Antonio Mariano Almeda, and Renato Bantug, Jr. (Tecson et al.) – were found guilty of
the crime of slight physical injuries and sentenced to 20 days of arrestomenor. Two of the
accused-appellants – FidelitoDizon and ArtemioVillareal were found guilty beyond
reasonable doubt of the crime of homicide under Article 249 of the Revised Penal Code.
ISSUES
WON physical injuries inflicted on Villa was a felonious act
WON the accused fraternity members were guilty of reckless imprudence resulting in
homicide
HELD
The intentional infliction of physical injuries on Villa was nonetheless a felonious act under
Articles 263 to 266 of the Revised Penal Code according to the trial court, although hazing
was not at the time punishable as a crime. Thus, in ruling against the accused, the court a
quo found that pursuant to Article 4(1) of the Revised Penal Code, the accused fraternity
members were guilty of homicide, as it was the direct, natural and logical consequence of
the physical injuries they had intentionally inflicted.
The CA modified the trial court’s finding of criminal liability. It ruled that there could have
been no conspiracy since the neophytes, including Lenny Villa, had knowingly consented to
the conduct of hazing during their initiation rites. The accused fraternity members,
therefore, were liable only for the consequences of their individual acts.
Consequently, the collective acts of the fraternity members were tantamount to

recklessness, which made the resulting death of Lenny a culpable felony. It must be
remembered that organizations owe to their initiates a duty of care not to cause them
injury in the process. Reckless imprudence or negligence consists of a voluntary act done
without malice, from which an immediate personal harm, injury or material damage results
by reason of an inexcusable lack of precaution or advertence on the part of the person
committing it. In this case, the danger is visible and consciously appreciated by the actor.
Since the NBI medico-legal officer found that the victim’s death was the cumulative effect of
the injuries suffered, criminal responsibility redounds to all those who directly participated
in and contributed to the infliction of physical injuries. Wherefore, the court ruled that the
accused are guilty of reckless imprudence resulting in homicide.

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Villareal Vs People

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Artemio Villareal vs.

People of the Philippines

Accused non-resident or alumni fraternity members FidelitoDizon and ArtemioVillareal

WON physical injuries inflicted on Villa was a felonious act

Consequently, the collective acts of the fraternity members were tantamount to

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