Case Summary (G.R. No. 171222)
Parties and Procedural History
Petitioner: The People of the Philippines, represented by the Office of the Special Prosecutor of the Office of the Ombudsman.
Respondents: PMMA school authorities and faculty members charged under Republic Act No. 8049 (Anti-Hazing Law).
Proceedings began with NBI findings and a provincial prosecutor’s resolution charging principal hazers (Alvarez et al.) before the Regional Trial Court (RTC) of Iba, Zambales. The Ombudsman later filed a separate criminal information before the Sandiganbayan against respondents as accomplices. The RTC dismissed the case against the principal accused, and the Sandiganbayan subsequently quashed the information against respondents in two resolutions dated 27 January and 3 August 2006. Petitions for certiorari were filed with the Supreme Court, leading to consolidated review.
Key Dates
• Indoctrination and Orientation Period: 2 May–1 June 2001
• Balidoy’s death: 3 May 2001
• NBI submission to provincial prosecutor: January 2002
• Provincial prosecutor’s resolution: 5 July 2002
• Filing of principal case in RTC: mid-2002
• RTC dismissal of principal case: 21 June 2005
• Filing of Special Prosecutor’s information against respondents: September 2005
• Sandiganbayan arraignment orders and motions to quash: December 2005–January 2006
• Sandiganbayan Resolutions quashing information: 27 January 2006 (respondents), 3 August 2006 (Velasco, Aris, Mabborang)
• Supreme Court petitions filed: March and October 2006
• Supreme Court decision: 18 February 2015
Applicable Law
• 1987 Philippine Constitution, Article III, Section 14 (right to be informed of nature and cause of accusation)
• Republic Act No. 8049 (Anti-Hazing Law), Sections 1 and 4
• Rules of Court, Rule 110 (sufficiency of the information) and Rule 117 (motions to quash and amendment)
Case Background and Facts
All PMMA probationary midshipmen were required to complete a mandatory “Indoctrination and Orientation Period.” On 3 May 2001, Balidoy died after alleged hazing rites. The NBI conducted a probe and forwarded its findings to the provincial prosecutor, who found probable cause to charge four midshipmen as principal violators of the Anti-Hazing Law. Simultaneously, the Ombudsman Investigator, agreeing with the provincial prosecutor, recommended charging school authorities as accomplices. The Office of the Special Prosecutor then filed separate criminal information against respondents before the Sandiganbayan.
Criminal Proceedings Against Principals and Accomplices
The RTC of Iba, Zambales, dismissed the RTC information against principal accused midshipmen (Alvarez et al.). Before respondents were arraigned in the Sandiganbayan, they moved to quash the information on multiple grounds—chiefly that the Anti-Hazing Law’s essential elements were not sufficiently alleged and that dismissal of the principal case foreclosed accomplice liability.
Sandiganbayan’s Quashal of Information
In SB Resolution I (27 Jan. 2006), the Sandiganbayan quashed the information against Bayabos et al. for two reasons: (1) absence of principal perpetrators, since the principal case had been finally dismissed, and (2) failure to allege that the acts were not part of the exempted military/police training. In SB Resolution II (3 Aug. 2006), it extended the quashal to Velasco, Aris, and Mabborang, applying the same rationale.
Issues for Supreme Court Review
- Can the prosecution of respondents for accomplice liability proceed despite the dismissal with finality of the principal case?
- Does the information contain all material averments constituting the crime of accomplice to hazing under RA 8049?
Independent Liability of Accomplices
Under established doctrine and enshrined in People v. Rafael, the liability of an accomplice is distinct from that of the principal. The dismissal or acquittal of the principal does not ipso facto extinguish the accomplice’s liability, provided the crime’s occurrence is duly established. The Sandiganbayan erred in outright dismissing the respondents solely for the absence of a standing principal prosecution.
Sufficiency of the Information under the Constitution and Rules
Article III, Section 14 of the 1987 Constitution and Rule 110 of the Rules of Court require that an information be sufficient: it must allege the acts or omissions constituting the offense in ordinary and concise language. A motion to quash under Rule 117, Section 3, may be grounded on the claim that “the facts charged do not constitute an offense,” tested by whether the averments establish the crime’s essential elements without considering extrinsic evidence.
Organization and Exemption under the Anti-Hazing Law
The term “organization” in RA 8049 explicitly includes government-owned educational institutions such as the PMMA. The statutory exemption for duly approved military and police training procedures is an affirmative defense to be pleaded by the accused, not an element the prosecution must negate in the information.
Defect in the Informati
Case Syllabus (G.R. No. 171222)
Facts
- Fernando C. Balidoy, Jr. was admitted as a probationary midshipman of Philippine Merchant Marine Academy (PMMA).
- Mandatory “Indoctrination and Orientation Period” ran from 2 May to 1 June 2001; Balidoy died on 3 May 2001.
- National Bureau of Investigation probed the death and forwarded findings to the Zambales provincial prosecutor.
- Assistant Provincial Prosecutor found probable cause and charged four midshipmen (Alvarez, Montez, Reyes, Simpas) as principals in hazing.
- Same prosecutor endorsed probable cause against PMMA school authorities (Aris, Bayabos, Ferrer, Doctor, Magsino, Mabborang, Velasco, Operio) as accomplices.
- Ombudsman Investigator concurred; administrative proceedings for grave misconduct were ordered.
- Office of Special Prosecutor filed with Sandiganbayan an Information charging the eight school authorities as accomplices to hazing under RA 8049.
Procedural History
- RTC of Iba, Zambales dismissed the case against the principal accused (Alvarez et al.); Order entered in Book of Entries of Judgment.
- Bayabos et al. moved to quash the Information for failure to allege essential elements under Anti-Hazing Law and because principal case was dismissed.
- Special Prosecutor opposed; contended Information was sufficient and that accomplice prosecution may proceed independently.
- Six days before arraignment, Sandiganbayan issued SB Resolution I (27 Jan 2006) quashing the Information against Bayabos et al. and dismissing the case.
- ENS Velasco later surrendered, adopted the same grounds, and Sandiganbayan issued SB Resolution II (3 Aug 2006) quashing his Information and dismissing the case against Aris and Mabborang ex proprio motu.
- Office of the Ombudsman filed petitions for certiorari with the