Case Digest (G.R. No. 166715) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People v. Aris (G.R. No. 171222 and G.R. No. 174786, February 18, 2015), probationary midshipman Fernando C. Balidoy, Jr. died on May 3, 2001 during the mandatory Indoctrination and Orientation Period at the Philippine Merchant Marine Academy (PMMA) in San Narciso, Zambales. The National Bureau of Investigation forwarded its findings to the Provincial Prosecutor of Zambales, which resulted in the filing of criminal charges for hazing against four midshipmen—Aldwin Alvarez, Leotharius C. Montez, Rudence G. Reyes, and Jed Nicholas S. Simpas—before the Regional Trial Court of Iba, Zambales. Simultaneously, the Office of the Special Prosecutor lodged an Information with the Sandiganbayan charging PMMA officials—Rear Admiral Virginio R. Aris, LTSG Dominador D. Bayabos, LTJG Manny G. Ferrer, LTJG Ronald G. Magsino, LTJG Kruzaldo G. Mabborang, LTJG Gerry P. Doctor, Ens. Dominador B. Operio, Jr., and Ens. Dennis S. Velasco—as accomplices to hazing under Republic Act No. 8049 (Anti- Case Digest (G.R. No. 166715) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relevant Law
- Petitioner: People of the Philippines.
- Respondents:
- RADM Virginio R. Aris; LTSG Dominador D. Bayabos; LTJG Gerry P. Doctor; LTJG Manny G. Ferrer; LTJG Kruzaldo G. Mabborang; LTJG Ronald G. Magsino; Ens. Dominador B. Operio, Jr.; Ens. Dennis S. Velasco.
- Principal accused (hazing perpetrators): Aldwin Alvarez et al.
- Governing statute: Republic Act No. 8049 (Anti-Hazing Law), esp. Sections 1 and 4 on hazing definitions and accomplice liability of school authorities.
- Factual Background
- Admission and Orientation
- Fernando C. Balidoy, Jr. admitted as probationary midshipman at Philippine Merchant Marine Academy (PMMA).
- Mandatory “Indoctrination and Orientation Period” scheduled from 2–1 June 2001.
- Death and Investigation
- Balidoy died on 3 May 2001 during orientation.
- NBI investigation forwarded findings to Zambales provincial prosecutor.
- Preliminary Charges
- Prosecutor finds probable cause to charge Alvarez et al. as principals in hazing.
- Prosecutor also finds probable cause to charge school authorities (respondents) as accomplices for failing to prevent hazing.
- Procedural History
- RTC of Zambales
- Filing of criminal case vs. Alvarez et al.
- Dismissal of charges against Alvarez et al.; entry of judgment.
- Sandiganbayan Proceedings
- Filing of Information vs. respondents as accomplices to hazing.
- Bayabos et al. move to quash, arguing defects in Information and mootness due to dismissal of principals.
- Special Prosecutor opposes; contends Information is sufficient and principal trial not prerequisite.
- Sandiganbayan Resolution I (27 Jan 2006) quashes Information against Bayabos et al. on grounds that no principals remain and defects in averments.
- Velasco surrenders, moves to quash; Sandiganbayan Resolution II (3 Aug 2006) likewise quashes Information against Velasco, Aris, Mabborang.
- Supreme Court Petitions
- Office of the Ombudsman files petitions against both Sandiganbayan resolutions.
- Consolidated before the Supreme Court (G.R. Nos. 171222 & 174786), argued and submitted for resolution.
Issues:
- Principal-Accomplice Dependency
- Can prosecution of respondents as accomplices proceed despite dismissal with finality of the case against principal perpetrators?
- Sufficiency of the Information
- Does the Information filed against respondents contain all material averments required under RA 8049 to charge them as accomplices to hazing?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)