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Villarba case

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Villarba vs. Court of Appeals
Case
G.R. No. 227777
Ponente
LEONEN, J
Decision Date
Jun 15, 2020
Omar Villarba is convicted for violating the Anti-Hazing Act after subjecting
Wilson Dordas III to hazing, resulting in physical and psychological suffering, and
the Supreme Court affirms his conviction, ruling that the amendment to the
information was not substantial and the evidence against him was sufficient.
Facts:

Omar Villarba was convicted for violating the Anti-Hazing Act after subjecting Wilson
Dordas III to hazing, resulting in physical and psychological suffering.

Villarba was a member of the Junior Order of Kalantiao, a fraternity based in the Central
Philippine University in Iloilo City.

The original information charged Villarba and other members of the fraternity with
subjecting Dordas to hazing or initiation, resulting in physical and psychological
suffering and injury.

The trial court found Villarba guilty and ordered him to pay compensatory damages,
moral damages, and attorney's fees to Dordas.
Issue:

Whether the amendment to the information was substantial and whether Villarba's right
to be informed of the nature and cause of the accusation against him was violated.

Whether the information was sufficient and whether the prosecution sufficiently proved
Villarba's guilt.
Ruling:

The amendment to the information was not substantial and did not require a second
arraignment. It did not change the crime charged or affect Villarba's defense.

The information was sufficient as it adequately apprised Villarba of the offense charged.
The lack of specific language regarding the acts as a prerequisite for admission to the
fraternity did not invalidate the information.

The prosecution sufficiently proved Villarba's guilt through the credible testimony of
Dordas, who provided a detailed and categorical narration of the hazing incident. The
lower courts' findings on witness credibility are entitled to great weight and respect.
Ratio:

A formal amendment does not change the crime charged or affect the accused's
defense. It adds nothing crucial for a conviction as to deprive the accused of the
opportunity to meet the new information. A second arraignment is not necessary for a
formal amendment.

The information need not reproduce the law verbatim in alleging the acts or omissions
that constitute the offense. As long as its language is understood, the accused's
constitutional right to be informed of the nature and cause of the accusation against
them stands unviolated.

The factual findings of the trial court, especially on witness credibility, are binding unless
substantial facts were overlooked, misapprehended, or misinterpreted. The testimony of
a single witness may suffice for conviction if it is deemed credible. Mere denial is
inherently a weak defense and cannot be accorded greater evidentiary weight than the
declaration of credible witnesses.
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