Artemio v. People of the Philippines
Subject:
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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:
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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.