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    Artemio Villareal V People Case Digest

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    anthony alferes
    The Supreme Court denied motions for reconsideration filed regarding the criminal case against members of the Aquila Legis Juris Fraternity involved in a hazing incident that resulted in death. While the OSG argued the penalty should be based on homicide due to the gross negligence and malicious nature of the hazing, the Court ruled reckless imprudence resulting in homicide was the proper finding since criminal intent to kill or harm could not be proven beyond reasonable doubt for the accused. Intentional felonies require proof of deliberate malicious intent, which was lacking in this case.

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    Artemio Villareal V People Case Digest

    Uploaded by

    anthony alferes
    30 views2 pages
    The Supreme Court denied motions for reconsideration filed regarding the criminal case against members of the Aquila Legis Juris Fraternity involved in a hazing incident that resulted in death. While the OSG argued the penalty should be based on homicide due to the gross negligence and malicious nature of the hazing, the Court ruled reckless imprudence resulting in homicide was the proper finding since criminal intent to kill or harm could not be proven beyond reasonable doubt for the accused. Intentional felonies require proof of deliberate malicious intent, which was lacking in this case.

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    Villareal v People Case Digest

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    Artemio Villareal v People Case Digest

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    The Supreme Court denied motions for reconsideration filed regarding the criminal case against members of the Aquila Legis Juris Fraternity involved in a hazing incident that resulted in death. While the OSG argued the penalty should be based on homicide due to the gross negligence and malicious nature of the hazing, the Court ruled reckless imprudence resulting in homicide was the proper finding since criminal intent to kill or harm could not be proven beyond reasonable doubt for the accused. Intentional felonies require proof of deliberate malicious intent, which was lacking in this case.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    30 views2 pages

    Artemio Villareal V People Case Digest

    Uploaded by

    anthony alferes
    The Supreme Court denied motions for reconsideration filed regarding the criminal case against members of the Aquila Legis Juris Fraternity involved in a hazing incident that resulted in death. While the OSG argued the penalty should be based on homicide due to the gross negligence and malicious nature of the hazing, the Court ruled reckless imprudence resulting in homicide was the proper finding since criminal intent to kill or harm could not be proven beyond reasonable doubt for the accused. Intentional felonies require proof of deliberate malicious intent, which was lacking in this case.

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    © All Rights Reserved
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    of 2

    Artemio v.

    People of the Philippines

    Subject:

     Motion for Partial Reconsideration filed by Petitioner Gerarda H. Villa – on cases of Escalona,
    Ramos, Saruca, and Adriano
     Motion for Reconsideration filed by the OSG
    While OSG agrees that neither Dizon, Tecson, Ama, Almeda, Bantug had felonious intent
    to kill (animus interficendi) nor intent to injure (animus iniurandi), penalty of the suspects
    should be based on Article 249 (Homicide) because the nature and gravity of the
    imprudence or negligence attributable to the accused was so gross, the accused conducted
    the initiation rites in such a malevolent and merciless manner that it clearly endangered
    the lives of the initiates and was thus equivalent to malice aforethought.
     Motions for Clarification or Reconsideration of Tecson et al

    Facts:

     Leonardo “Lenny” Villa died from hazing during initiation at the hands of fellow brothers in
    Aquila Legis Juris Fraternity
     Criminal Case was filed against 35 Aquilans
    o RTC decision:
     26 of the accused  guilty beyond reasonable doubt of homicide
     9 of the accused  acquitted
    o CA decision:
     19  acquitted
     15  guilt not established beyond reasonable doubt
     Escalona, Ramos, Saruca, and Adriano  dismissed criminal case on the
    ground that their right to speedy trial was violated
     Tecson, Ama, Almeda, Bantug  guilty of crime of slight physical injuries
     Dizon and Villareal  homicide
    o SC decisions before above motions
     Upheld decision on Escalona, Ramos, Saruca, Adriano
     Affirmed CA decision with modification i.e. Dizon, Tecson, Ama, Almeda, Bantug
    are guilty of reckless imprudence resulting to homicide

    Issue: Whether penalty imposed on Tecson, Ama, Almeda, Bantug should have corresponded to that for
    intentional felonies

    Ruling: All motions are DENIED.

    Ruling relevant to topic: Motion by OSG denied. As ruled in many Supreme Court cases, Mere infliction
    of physical injuries, absent malicious intent does not make a person automatically liable for an
    intentional felony.
    What is the concept of criminal intent as an element of intentional felony?

    Criminal or malicious intent is necessary for intentional felonies to exist. intentional felonies concern
    those wrongs in which a deliberate malicious intent to do an unlawful act is present. If there is no
    criminal intent, the accused cannot be found guilty of an intentional felony.

    Culpable felonies involve those wrongs done as a result of an act performed without malice or criminal
    design;

    Why were the accused in this case held liable for reckless imprudence resulting in homicide rather
    than homicide?

    The criminal/malicious intent of the suspects to kill and to injure was not proven beyond reasonable
    doubt. Mere infliction of physical injuries, absent malicious intent does not make a person automatically
    make a person liable for an intentional felony.

    Reckless imprudence consists in voluntary, but without malice, doing or falling to do an act from which
    material damage results by reason of inexcusable lack of precaution on the part of the person
    performing or failing to perform such act, taking into consideration his employment or occupation,
    degree of intelligence, physical condition and other circumstances regarding persons, time and place.

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