G.R. No. 227777 - Villarba vs. Court of Appeals

Omar Villarba (petitioner) was charged with violating Republic Act No. 8049 (Anti-Hazing Act of 1995) alongside members of the Junior Order of Kalantiao, a Central Philippine University fraternity.
The original Information (2003) alleged that on September 15, 2001, in Iloilo City, the accused “did . . . subject one Wilson Dordas to hazing or initiation . . . which resulted in his confinement and operation and prevented him from engaging in his habitual work for more than ninety (90) days.”

After arraignment and plea of not guilty, the Information was formally amended to correct the victim’s name by adding the suffix “III” to “Wilson Dordas.”
No second arraignment was conducted on the amended Information; pre-trial and trial proceeded under the original plea.

Wilson Dordas III testified that Villarba recruited him, assured no harm, then subjected him and co-applicants to humiliating tasks at campus and final rites at Racrap Beach Resort, including forced consumption of hot peppers, physical punishments, blindfolded punches (one by Villarba), dripping hot wax, and resulted in liver damage requiring surgery.

Villarba admitted recruitment and rites but insisted only mild exercises (sit-ups, push-ups, jogging) were performed and no physical harm was inflicted.

Found Villarba and co-accused guilty beyond reasonable doubt; imposed indeterminate prison term (10 years +1 day to 12 years) and awarded compensatory, moral damages, and attorney’s fees to Dordas III.

Affirmed conviction, holding the Information sufficient despite omission of “prerequisite to admission” phrase and formal amendment of victim’s name; no prejudice or surprise to the accused; Dordas’s testimony credible despite minor inconsistencies.

Whether the amendment to the Information (adding “III” to the victim’s name) was substantial, requiring a new arraignment.
Whether the Information was insufficient or void for failing to allege that the hazing was a prerequisite to membership.
Whether the prosecution sufficiently proved Villarba’s guilt beyond reasonable doubt.