Villareal v. People

ARTEMIO VILLAREAL v.
PEOPLE OF THE PHILIPPINES

G.R. No. 151258, February 1, 2012
FIDELITO DIZON v. PEOPLE OF THE PHILIPPINES
G.R. No. 155101, February 1, 2012
PEOPLE OF THE PHILIPPINES v. COURT OF APPEALS ET AL.
G.R. No. 154954, February 1, 2012
GERARDA VILLA v. MANUEL ESCALONA II ET AL.
G.R. No. 178057 and 178080, February 1, 2012
Doctrine
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.
Facts
In February 1991, 7 freshmen law students of Ateneo de Manila School of Law expressed their
intention to join Aquila Fraternity. On February 8, they were briefed by Michael Musngi that
there would physical beatings and psychological pressure during the 3-day initiation rites.
Thereafter, they were brought to Amelda Compound in Caloocan City for the commencement of
initiation rites. They were subjected to “Indian Run”, “Bicol Express”, “Rounds” and “Auxies
Privilege Round”. On February 9, they were made to present comic plays, rough basketball and
memorize and recite Aquila principles (with every wrong answer, they’d be hit on arms and
legs). In the afternoon, they were again subjected to physical and psychological torment. After
the initiation rites on the 2nd day officially ended, Fidelito Dizon and Artemio Villareal demanded
that it be reopened. The neophytes were subjected to paddling. Lenny received 7 paddle blows.
After the initiation rites again officially ended, the neophytes were roused by Lenny’s condition
(shivering and mumbling) until the Aquilans decided to take him to the hospital. He was
pronounced dead on arrival. On January 10, 2002, CA modified the decision: 19 were acquitted,
4 (Tecson, Amelda, Ama and Bantug Jr.) were convicted of slight physical injuries and 2 (Dizon
and Villareal) were convicted of homicide. (1 died)
Issues
1. Whether trial court’s forfeiture of Dizon’s right to present evidence constitutes denial of due
process?
2. Whether CA committed grave abuse of discretion when it dismissed the case against
Escalona, Ramos, Saruca, and Adriano for violation of right of the accused to speedy
trial?
3. Whether CA committed grave abuse of discretion when it set aside the finding of
conspiracy by trial court and adjudicated the liability of each accused according to
individual participation?
4. Whether CA committed grave abuse of discretion when it pronounced Tecson, Ama,
Almeda, and Bantug guilty only of slight physical injuries?
5. Whether accused Dizon is guilty of homicide?
Ruling
1. No. SC upheld trial court’s order that Dizon’s failure to present evidence amounts to waiver
of that right. Where there is no material inadequacy nor procedural irregularity in the case,
the trial court’s decision is affirmed.
2. No. SC upheld CA’s decision to dismiss Escalona, Ramos, Saruca, and Adriano’s case on
the basis of their right to speedy trial. They were arraigned on Nov. 29, 1993. The initial trial
of the case only commenced on Mar. 28, 2005.
3. No. Malicious intent is required in conspiracy (intentional). Art. 8 says "conspiracy exists
when 2 or more persons come to an agreement concerning the commission of a felony and
decide to commit it". "Come to an agreement" means intent to injure or animus iniurandi. No
proof.
4. No. Art. 4 says that the perpetrator shall be liable for the consequences of an act, even if its
result is different from that intended. In this case, they contributed to Lenny’s death.
5. No. Malicious intent is required in homicide (intentional). Dizon’s statements were only part
of psychological aspect of the rites, not motive (stolen parking lot of his father by Lenny’s
father and death of his NPA brother by Bien’s). There was assistance from auxiliaries. No
other weapon than paddle. No proof Lenny was targeted. All who wished to join went
through the same. No proof beyond reasonable doubt that they had intent to kill or animus
interficendi.
Dizon, Tecson, Amelda, Ama and Bantug Jr. found guilty of reckless imprudence
resulting in homicide. SC considered the nature of hazing, context of the case and absence of
Anti-Hazing Law at that time. There was consent on Lenny’s part. The physical beatings and
psychological threats were part of the traditional initiation rite. No intent to kill or injure on the
part of Aquilans. But death from hazing does not absolve criminal liability. In this case, it is
reckless imprudence. Lenny’s death was caused by cardiac failure due to multiple traumatic
injuries. Some Aquilans were intoxicated. The presence of senior members (Dizon and Villareal)
aggravated the circumstances. Hence, they are guilty of reckless imprudence resulting in
homicide.

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ARTEMIO VILLAREAL v.

PEOPLE OF THE PHILIPPINES

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