Title
Villareal vs. People
Case
G.R. No. 151258
Decision Date
Dec 1, 2014
Ateneo law student Lenny Villa died during fraternity hazing in 1991; SC convicted members for reckless imprudence, upheld acquittals, and nullified probation grants.

Case Digest (G.R. No. 195147)
Expanded Legal Reasoning Model

Facts:

  • Factual Antecedents
    • In February 1991, seven neophytes of the Aquila Legis Juris Fraternity at Ateneo Law School underwent a three-day hazing ritual involving physical beatings (“Indian Run,” “Bicol Express,” “Rounds,” “Auxies’ Privilege Round”), psychological torment, and indoctrination.
    • On the second night, after additional paddling insisted upon by alumni members Fidelito Dizon and Artemio Villareal, Leonardo “Lenny” Villa collapsed, was rushed to the hospital, and pronounced dead on arrival.
  • Procedural History
    • Criminal Case No. C-38340(91) was filed against 35 fraternity members. RTC Branch 121 convicted 26 jointly tried accused of homicide (reclusion temporal). The remaining nine were tried later.
    • On January 10, 2002, the CA (CA-G.R. CR No. 15520) set aside a conspiracy finding, acquitted 19, convicted Dizon and Villareal of homicide (10–17 years), and found Tecson, Ama, Almeda, Bantug guilty of slight physical injuries (20 days arresto menor).
    • A separate CA decision (CA-G.R. S.P. Nos. 89060 & 90153) dismissed charges against Escalona et al. for speedy-trial violation.
    • On February 1, 2012, the SC in Villareal v. People modified convictions: found Dizon, Almeda, Ama, Bantug, Tecson guilty of reckless imprudence resulting in homicide (4 months–4 years+2 months under Art. 365 RPC), affirmed other acquittals and dismissals, and closed Case No. 151258.
    • Motions for reconsideration/clarification were filed by the People (OSG), Gerarda Villa, and respondents Almeda, Ama, Bantug, Tecson.

Issues:

  • Did the CA commit grave abuse of discretion amounting to lack or excess of jurisdiction when it dismissed Escalona et al.’s case for speedy-trial violation?
  • Should the penalty imposed on Tecson et al. have been equivalent to that for intentional felony (dolo) rather than for reckless imprudence (culpa)?
  • Did Tecson et al.’s completion of probation discharge them from criminal liability and terminate the cases?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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