Case Digest (G.R. No. 227695)
Facts:
On October 22, 2009, at a farm in Area C, Dasmariñas, Cavite, Carlos Paulo Bartolome y Ilagan and Joel Bandalan y Abordo, alleged members of the Tau Gamma Phi Fraternity, were identified as the only two of three males who brought 18-year-old neophyte John Daniel Samparada y Llamera to Estrella Hospital after he lost consciousness. Medical and police officers observed bruises on his thighs consistent with hazing. Investigating officers recovered from Bartolome a document bearing fraternity markings and his handwritten name. The Office of the City Prosecutor of Imus, Cavite charged both petitioners with violating Section 4(a) of Republic Act No. 8049 (Anti-Hazing Law). They pleaded not guilty; after trial, the Regional Trial Court (RTC) of Imus, Cavite, convicted them of hazing resulting in death and sentenced them to reclusion perpetua with indemnity and damages. On August 30, 2016, the Court of Appeals (CA) affirmed the conviction but increased the damages. A motion for reconsidCase Digest (G.R. No. 227695)
Facts:
- Procedural Background
- Petitioners Carlos Paulo Bartolome y Ilagan and Joel Bandalan y Abordo were charged before the RTC of Imus, Cavite with violation of Section 4(a) of R.A. 8049 (Anti-Hazing Law) for allegedly hazing and causing the death of neophyte John Daniel Samparada y Llamera.
- The RTC convicted them and imposed reclusion perpetua; the Court of Appeals affirmed the conviction with modified civil damages. Petitioners then filed a petition for review on certiorari under Rule 45 of the Rules of Court before the Supreme Court.
- Factual Background
- Prosecution’s Version
- On October 22, 2009, Estrella Hospital alerted the police that a hazing victim with severe bruises had been brought in.
- SPO2 Patambang and two other officers investigated, identified petitioners as fraternity members, recovered a document bearing “Tau Gamma Phi” and Bartolome’s name, and learned the hazing occurred in Area C, Dasmariñas, Cavite.
- Petitioners allegedly admitted the existence of hazing and brought Samparada to the hospital after he lost consciousness.
- Defense’s Version
- Petitioners claimed they met Samparada while night-swimming at a friend’s house, where he suddenly fell, hit his head, and complained of breathing difficulty.
- They said they immediately took him to the hospital and that police officers coerced them into admitting hazing participation.
Issues:
- Whether the circumstantial evidence presented was sufficient to prove petitioners’ guilt beyond reasonable doubt for hazing under R.A. 8049.
- Whether the statutory presumption of guilt under Section 4, paragraph 6 of R.A. 8049 violates the constitutional presumption of innocence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)