Villareal; Dizon VS.

People

Quick Facts:

-7 freshmen law students of Ateneo De Manila University wanted to join Aquila Fraternity.
-The neophytes were met by the Aquilans, they were informed that initiation rites will involve
beatings and they can quit anytime.
-1st day of initiation: many beatings
-2nd day of initiation: present comic plays, rough basketball and memorize the Aquila Frat
principles.
-Accused Villareal and Dizon demanded that the rites be reopened. They then subjected the
neophytes to paddling.
-Lenny received several paddle blows. After last session of beatings, Lenny could no longer
walk. After Lennys shivering and mumblings, the Aquilans helped him through a sleeping bag
to keep him warm. When his condition worsened, he was rushed to the hospital. He was dead
on arrival.

Issue:
-WON Dizon et.al had criminal intent in the death of Lenny.

Ruling:
-Accused Dizon and Tecson et.al did not have criminal intent. Hence, we rule that the imposable
penalty is what is applicable to the crime of reckless imprudence resulting in homicide as
defined and penalized under Article 365 of the RPC.

Legal Antecedents:

RTC: DISMISSED VILLAREAL, DIZON ET AL

COURT OF APPEALS: Two of the accused-appellants Fidelito Dizon and Artemio Villareal were
found guilty beyond reasonable doubt of the crime of homicide under Article 249 of the Revised
Penal Code.

NOTE: There are so many cases involved; I just took the important principles of the SC in relation to
the syllabus.

Syllabus Principles: Classical Theory & meaning and rationale of Article 4, Paragraph 1 of the
RPC.

Classical Theory:
The RPC belongs to the classical school of thought.
Classical Theory states that humans are rational and calculating beings who guide their actions
with reference to the principles of pleasures and pain. They refrain from criminal acts if
threatened with punishment sufficient to cancel the hope of possible gain or advantage in
committing the crime.

Meaning and rationale of Article 4, Paragraph 1

Art. 4. Criminal liability Criminal liability shall be incurred:
1. By any person committing a felony (delito) although the wrongful act done be
different from that which he intended.
2. By any person performing an act which would be an offense against persons or
property, were it not for the inherent impossibility of its accomplishment or on
account of the employment of inadequate means or ineffectual means.

Case of Villareal defined the following

1. Culpable felonies: wrongs done as a result of an act performed w/o malice or criminal
design.
Reckless Imprudence: consists in voluntary, but without malice, doing or failing to do an
act which material damage results by reason of inexcusable lack of precaution.
Test for Negligence:
The test for determining whether or not a person is negligent in doing an act is as
follows: Would a prudent man in the position of the person to whom negligence is
attributed can foresee harm to a person injured by reason of consequence of the
course about to be pursued? If so, the law imposes on the doer the duty to take
precaution against the mischievous results of the act. Failure to do so constitutes
negligence.
2. Intentional felonies in order for an intentional felony to exist, it is necessary that the
act be committed by means of dolo or malice
Elements of dolo or malice
1. Freedom
2. Intelligence
3. Intent

Element of intent is the state of mind accompanying an act, especially a forbidden act. It refers
to the purpose of the mind and the resolve with which a person proceeds.

Principle: Actus non facit reum, nisi mens sit rea a crime is not committed if the mind of the
person performing the act complained of is innocent.

Article 4 paragraph 1 refers to intentional felonies.

Jeffrey Liang VS People of the Philippines

Quick Facts
-Petitioner is a Chinese national who was employed as an Economist by Asian Development
Bank (ADB)
-