Primary Holding

The Supreme Court found the accused fraternity members guilty of reckless imprudence resulting in homicide, emphasizing that the death of Lenny Villa was the cumulative effect of the physical injuries inflicted during the initiation rites. The Court also dismissed the case against Artemio Villareal due to his death, extinguishing his criminal liability.

Background

Lenny Villa, a law student at Ateneo de Manila University, died during the initiation rites of the Aquila Legis Juris Fraternity in February 1991. The initiation involved physical beatings and psychological pressure, leading to Villa's death from cardiac failure due to multiple traumatic injuries. The case led to the enactment of the Anti-Hazing Law in 1995.

Facts

• 1. Lenny Villa and six other neophytes underwent initiation rites by the Aquila Legis Fraternity.
• 2. The initiation involved physical beatings, psychological pressure, and traditional rituals like the "Indian Run" and "Bicol Express."
• 3. Lenny Villa died from cardiac failure due to multiple traumatic injuries sustained during the initiation.
• 4. The trial court convicted 26 accused of homicide, but the Court of Appeals acquitted most of them, convicting only a few for slight physical injuries and two for homicide.

Arguments of the Petitioners

• 1. Artemio Villareal argued that he was denied due process and that his conviction was not supported by proof beyond reasonable doubt.
• 2. Fidelito Dizon argued that he was denied due process when the trial court forfeited his right to present evidence and that his actions were part of traditional initiation rites.
• 3. The Solicitor General argued that the Court of Appeals erred in acquitting most of the accused and in not finding conspiracy among the fraternity members.

Arguments of the Respondents

• 1. The respondents, including the People of the Philippines, argued that the accused should be held liable for the death of Lenny Villa, either through conspiracy or individual participation in the initiation rites.

Issues

• 1. Whether the forfeiture of Dizon's right to present evidence constituted a denial of due process.
• 2. Whether the Court of Appeals committed grave abuse of discretion in dismissing the case against some accused for violation of the right to speedy trial.
• 3. Whether the Court of Appeals erred in setting aside the trial court's finding of conspiracy and adjudicating liability based on individual participation.
• 4. Whether Dizon is guilty of homicide.
• 5. Whether the Court of Appeals erred in convicting some accused only of slight physical injuries.

Ruling

• 1. The Supreme Court ruled that the accused fraternity members were guilty of reckless imprudence resulting in homicide, as the death of Lenny Villa was the cumulative effect of the physical injuries inflicted during the initiation rites.
• 2. The Court found that the accused acted with recklessness, failing to take proper precautions to prevent harm to the neophytes.
• 3. The Court modified the penalties, sentencing the accused to an indeterminate prison term and ordering them to pay civil indemnity and moral damages to the heirs of Lenny Villa.
• 4. The Court dismissed the case against Artemio Villareal due to his death, extinguishing his criminal liability.

Doctrines

• 1. Reckless Imprudence: The Court applied the doctrine of reckless imprudence, finding that the accused failed to exercise the necessary care to prevent harm during the initiation rites.
• 2. Double Jeopardy: The Court discussed the principle of double jeopardy, noting that the dismissal of the case against some accused for violation of the right to speedy trial amounted to acquittal.
• 3. Mala in se vs. Mala prohibita: The Court distinguished between crimes that are inherently wrong (mala in se) and those that are wrong because they are prohibited by law (mala prohibita), emphasizing that hazing was not traditionally considered a crime before the Anti-Hazing Law.

Key Excerpts

• 1. "The absence of malicious intent does not automatically mean, however, that the accused fraternity members are ultimately devoid of criminal liability."
• 2. "The collective acts of the fraternity members were tantamount to recklessness, which made the resulting death of Lenny a culpable felony."

Precedents Cited

• 1. People v. Penesa: Cited to explain that slight physical injuries require proof of incapacity for labor or medical attendance, which was not applicable in this case due to the victim's death.
• 2. People v. Carmen: Cited to illustrate that without malicious intent, the accused cannot be held liable for intentional felonies but may be liable for reckless imprudence.
• 3. Crisostomo v. Sandiganbayan: Cited to emphasize the importance of the accused's right to present evidence and the need for a clear waiver of that right.

Statutory and Constitutional Provisions

• 1. Article 89(1) of the Revised Penal Code: Discussed the extinction of criminal liability upon the death of the accused.
• 2. Article 4 of the Revised Penal Code: Discussed the liability for the consequences of an act, even if the result is different from what was intended.
• 3. Article 365 of the Revised Penal Code: Discussed the penalties for reckless imprudence resulting in homicide.