FACTS:

The petitioners, Carlos Paulo Bartolome and Joel Bandalan, were accused of violating Section 4(i) of Republic Act No. 8049 (Anti-Hazing Law). They were alleged to have conducted initiation rites and subjected neophyte John Daniel Samparada to physical suffering, which led to his untimely death. The police officers who investigated the incident found bruises on Samparada's thighs, indicating that he was a victim of hazing. Petitioners were identified as members of the Tau Gamma Phi Fraternity and admitted to participating in the hazing. However, the defense argued that Samparada's injuries were not caused by hazing, but rather by an accident during a night swimming outing.

The Regional Trial Court (RTC) convicted the petitioners, sentencing them to reclusion perpetua and ordering them to pay indemnity and temperate damages to Samparada's heirs. The Court of Appeals (CA) affirmed the RTC's decision, finding that there was sufficient evidence to establish petitioners' participation in the hazing incident. The CA modified the award of damages but upheld the conviction of the petitioners.

The accused-appellants filed a motion for reconsideration, but the CA denied it. Hence, they filed a petition for review on certiorari before the Supreme Court. The petition raised two assignment of errors. First, they argued that the CA decided the case based on erroneous and inadmissible circumstantial evidence. Second, they contended that the CA wrongly relied on the presumption of guilt under RA 8049 instead of the constitutional presumption of innocence.

In response, the Office of the Solicitor General (OSG) countered that the offense charged may be proven by circumstantial evidence. The OSG contended that the prosecution's evidence, including the testimonies of its witnesses, formed a chain of circumstances that incriminated the accused-appellants in the killing of Samparada.

The Supreme Court held that the accused-appellants are seeking relief through a petition for review on certiorari under Rule 45 of the Rules of Court. While Rule 45 petitions may raise only pure questions of law, the Court has the duty to correct errors found in the judgment appealed from, especially in criminal cases.

After a careful review of the case and the evidence presented, the Supreme Court was not convinced that the accused-appellants were guilty beyond reasonable doubt of the offense of hazing. The Court emphasized that in criminal cases, proof beyond reasonable doubt is required to support a judgment of conviction. The lack of direct evidence linking the accused-appellants to Samparada's death, and the use of circumstantial evidence in their conviction, led the Court to reverse the appealed decision and acquit the accused-appellants.

The case involves the conviction of the petitioners for hazing under Section 4(a) of RA 8049. The trial court convicted the petitioners based on several circumstances presented during the trial. These circumstances include the victim's cause of death, which was determined to be due to blunt traumatic injuries; the presence of the petitioners and the victim at Ivan's house when the victim lost consciousness; the petitioners and Nicodemus Tolentino bringing the victim to Estrella Hospital; the seizure of a document related to a fraternity, specifically Tau Gamma Phi Fraternity, from one of the petitioners; and the information provided by the petitioners during the investigation that the incident happened in a field in Dasmariñas, Cavite. SPO2 Patambang's testimony further linked the petitioners to the fraternity and the hazing incident. The Court of Appeals affirmed the conviction, stating that the circumstances clearly pointed to the petitioners' involvement in hazing. However, the Supreme Court was not convinced that the testimony and circumstances were sufficient to establish the petitioners' guilt beyond reasonable doubt for the offense of hazing. The Supreme Court also noted the enactment of RA 11053, which amended the Anti-Hazing Law and imposed more severe penalties for hazing. The intent of the Anti-Hazing Law is to deter hazing and make it unacceptable.

The case involves the crime of hazing, which the court describes as a deplorable form of violence that has no place in any civil society, particularly in organizations that claim to be brotherhoods. The court acknowledges the difficulty in proving hazing due to the culture of silence, secrecy, and blind loyalty among fraternity members. Hazing is often shrouded in secrecy, making it necessary for the prosecution to rely on circumstantial evidence. The court emphasizes that hazing, like any other crime, can be proven through circumstantial evidence and conviction is still possible even with a single credible witness. However, the court also upholds the presumption of innocence and the requirement of proof beyond reasonable doubt. In this particular case, the court finds that the circumstantial evidence presented by the prosecution is insufficient to establish the guilt of the accused for violating the Anti-Hazing Law.

ISSUES:

1. Whether the elements of hazing under RA 8049 were sufficiently established.

2. Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the petitioners beyond reasonable doubt.

3. Whether the evidence presented by the prosecution is sufficient to prove the elements of hazing.

4. Whether the prosecution has established that the injuries sustained by the victim were caused by the defendants.

5. Whether the circumstantial evidence presented by the prosecution is sufficient to establish the elements of hazing.

6. Whether an unbroken chain of circumstances was produced that leads to one fair and reasonable conclusion pointing to the petitioners as the persons liable for the death of the victim.

7. Whether the petitioner is guilty of hazing.

8. Whether there is prima facie evidence of participation in hazing.

9. Whether or not the prosecution has proven the guilt of the accused beyond reasonable doubt for violation of Section 4(a) of Republic Act No. 8049.

10. Whether or not the accused should be acquitted due to the failure of the prosecution to meet the required quantum of proof.

RULING:

1. The Court finds reasonable doubt on the guilt of the petitioners for the violation of the Anti-Hazing Law. The circumstantial evidence presented by the prosecution is insufficient for their conviction. The prosecution failed to establish the elements of hazing under RA 8049, namely: (1) that there is an initiation rite or practice as a prerequisite for admission into membership in a fraternity, sorority, or organization, (2) that there must be a recruit, neophyte, or applicant of the fraternity, sorority, or organization, and (3) that the recruit, neophyte, or applicant is placed in some embarrassing or humiliating situations or subjected to physical or psychological suffering or injury. The testimony of the witnesses and the circumstances adopted during the trial were not able to demonstrate the concurrence of these elements. Furthermore, the assessment of the hospital staff and the police officers regarding the cause of the victim's injuries remained inconclusive.

2. The Court held that the evidence presented by the prosecution is not sufficient to prove the elements of hazing. The prosecution failed to establish the first element, which is that the fraternity conducted an initiation rite or practice as a precondition for admission. There is also a failure to establish the second element, which is that the victim was a recruit, neophyte, or applicant of the fraternity. Without these elements, the offense of hazing cannot be proven.

3. The court also held that the prosecution has not established that the injuries sustained by the victim were caused by the defendants. The circumstantial evidence presented does not exclude the possibility that some other person or persons have caused the injuries. Therefore, the defendants cannot be held responsible for the injuries sustained by the victim.

4. The circumstantial evidence presented by the prosecution failed to establish the elements of hazing.

5. There was a failure on the part of the prosecution to produce an unbroken chain of circumstances that leads to one fair and reasonable conclusion pointing to the petitioners as the persons liable for the death of the victim.

6. The court held that the prosecution failed to establish with moral certainty that the petitioner is guilty of hazing. The evidence presented by the prosecution did not prove that the injuries inflicted on the victim were done during an initiation rite conducted by the fraternity.

7. The court ruled that the prima facie presumption of participation in hazing found in the law does not apply in this case. The prosecution failed to prove that a hazing incident occurred, thus the presumption cannot be invoked.

8. The Court orders the acquittal of the petitioners for failure of the prosecution to prove their guilt beyond reasonable doubt for violation of Section 4(a) of Republic Act No. 8049.

PRINCIPLES:

• Hazing, like any other felony, need not be proven by direct evidence; it may be sufficiently proven by circumstantial evidence.

• In all criminal prosecutions, proof of guilt beyond reasonable doubt is required in order to attain a conviction.

• Every person accused of any crime is considered innocent until the contrary is proven.

• In the appreciation of circumstantial evidence, the circumstances must be proved, and not presumed.

• The circumstantial evidence must exclude the possibility that some other person has committed the offense charged.

• Conviction based on circumstantial evidence does not necessarily rest on the number of circumstances established during the trial.

• The prosecution must establish circumstances that occurred before and during the alleged hazing incident.

• In order to convict an accused based on circumstantial evidence, there must be an unbroken chain of circumstantial evidence leading to one fair and reasonable conclusion pointing to the guilt of the accused, to the exclusion of others.

• It is the duty of the prosecution to present its case with clarity and persuasion, ensuring that conviction is justified with moral certainty.

• The court is guided by the principles underlying the law on hazing, which aims to address the issue of violent initiation rites in educational institutions and communities.

• The accused enjoys the constitutional presumption of innocence and his guilt must be proven beyond reasonable doubt in order to attain a conviction.

• Careful case-build up and proper presentation of evidence are necessary to overcome the presumption of innocence and prove guilt beyond reasonable doubt.

• Every circumstance favoring the accused's innocence must be duly taken into account.

• Strongest suspicion must not be permitted to sway judgment.

• The conscience must be satisfied that only the accused could be responsible for the offense charged.