FACTS:

In February 1991, seven freshmen law students from Ateneo de Manila University School of Law, including Leonardo “Lenny” Villa, expressed their intention to join the Aquila Legis Juris Fraternity. The neophytes were Caesar "Bogs" Asuncion, Samuel "Sam" Belleza, Bienvenido "Bien" Marquez III, Roberto Francis "Bert" Navera, Geronimo "Randy" Recinto, Felix Sy, Jr., and Villa. On the evening of February 8, 1991, fraternity members met the neophytes at the Ateneo Law School lobby and took them to Rufo’s Restaurant for dinner. Post dinner, they moved to Michael Musngi's house, also a fraternity member, where they were briefed on the initiation rites, including the possibility of physical beatings and the option to quit at any time. Initiation was slated to last three days and began at the Almeda Compound in Caloocan City.

Even before getting off the van, the neophytes faced threats and insults from fraternity members. Once they alighted from the van and moved towards the pelota court in the compound, they endured traditional initiation rituals. These included enduring physical blows while running through a gauntlet (termed "Indian Run"), being jumped on while seated with legs outstretched ("Bicol Express"), receiving blows while held by auxiliaries ("Rounds"), and being inflicted with pain by designated auxiliaries ("Auxies' Privilege Round"). The initiation continued the next day, involving various forms of physical and psychological torture, which escalated in intensity upon the insistence of non-resident members, Fidelito Dizon and Artemio Villareal. Subjection to intense paddling by Villareal and Dizon left Lenny Villa in severe pain and difficulty breathing. After the final physical beatings, Villa could no longer walk and had to be carried by auxiliaries.

Later, Lenny began shivering and mumbling incoherently. Despite initial dismissals of his condition by some members, Villa was soon rushed to the hospital where he was pronounced dead on arrival. Consequently, 35 fraternity members were charged with homicide, with cases against 26 of them proceeding to trial while those against the remaining nine were held in abeyance. On November 8, 1993, the trial court found the 26 guilty of homicide. However, upon appeal, the Court of Appeals modified the decision, acquitting 19 and reducing the charges against four to slight physical injuries while retaining homicide charges against Dizon and Villareal. The Supreme Court later took on consolidated cases to resolve complex issues related to the right to a speedy trial, the forfeiture of the right to present evidence, and the interpretation of criminal liability arising from the hazing-related death of Lenny Villa.

ISSUES:

1. Whether the forfeiture of petitioner Dizon's right to present evidence constitutes denial of due process;

2. Whether the CA committed grave abuse of discretion, amounting to lack or excess of jurisdiction, when it dismissed the case against Escalona, Ramos, Saruca, and Adriano for violation of the right of the accused to speedy trial;

3. Whether the CA committed grave abuse of discretion, amounting to lack or excess of jurisdiction, when it set aside the finding of conspiracy by the trial court and adjudicated the liability of each accused according to individual participation;

4. Whether accused Dizon is guilty of homicide;

5. Whether the CA committed grave abuse of discretion when it pronounced Tecson, Ama, Almeda, and Bantug guilty only of slight physical injuries.

RULING:

1. Yes. The denial of Dizon's Constancia by the trial court and subsequent forfeiture of his right to present evidence amounted to a denial of due process. The right of the accused to present evidence is guaranteed by the Constitution, and the failure to permit Dizon to present his evidence was not justified.

2. No. The Supreme Court found no grave abuse of discretion in the CA's dismissal of the case on grounds of violation of the accused’s right to speedy trial. The unexplained interval or inactivity of the Sandiganbayan for almost 12 years since the arraignment of the accused, among other factors, constituted an unreasonable delay in the disposition of cases, thus violating their right to a speedy trial.

3. No. The Supreme Court did not find grave abuse of discretion on this ground and noted the due process in assessing individual liabilities sans conspiracy.

4. No. The Supreme Court ruled that there was no proof beyond a reasonable doubt of the animus interficendi (intent to kill) or animus iniuriandi (malicious intent to inflict injury). Instead, criminal liability was based on reckless imprudence resulting in homicide.

5. Yes. The CA committed grave abuse of discretion by convicting Tecson, Ama, Almeda, and Bantug only for slight physical injuries despite acknowledging the serious nature of the injuries inflicted. The correct criminal liability was reckless imprudence resulting in homicide based on the cumulative effect of the injuries leading to Lenny Villa's death.

PRINCIPLES:

1. Right to Due Process

   • The accused's right to present evidence and be heard is fundamental and constitutionally guaranteed.

2. Right to Speedy Trial

   • Determine whether delays are vexatious, capricious, or oppressive; long periods of inactivity without justification constitute a violation.

3. Double Jeopardy

   • Final acquittal is immediately final and an appeal or reconsideration of acquittal violates this principle, except in cases where there is grave abuse of discretion.

4. Animus Interficendi and Animus Iniuriandi

   • Proof beyond reasonable doubt of malicious intent (either to kill or to injure) is mandatory for intentional felonies.

5. Reckless Imprudence

   • Liability for felony through fault requires voluntary acts done without malice but accompanied by evident lack of precaution or foresight.

6. Civil Indemnity

• Automatically awarded for the death of the victim, aside from moral damages for grief suffered by the heirs.

13. Hazing

• Unique criminal context (ambiguous intent), distinguished in legislative considerations as potentially different from typical crimes under mala prohibita vs. mala in se classification pre-1995 Anti-Hazing Law.

15. Procedural Doctrine

• Errors that do not necessarily invalidate findings (e.g., invalid waiver or procedural lapses) do not automatically lead to remand or case reopening if substantial justice is served based on adequate factual evidence.