Villareal vs.

People
GR No. 151258
February 1, 2012
664 scra
FACTS: Seven Freshmen Law students of Ateneo de Manila University School of Law have
been initiated by the Aquila Legis Juris Fraternity on February 1991. The initiation rites started
when the neophytes were met by some members of the mentioned fraternity at the lobby of the
Ateneo Law School. They were consequently brought to a house and briefed on what will be
happening during the days when they will be initiated. They were informed that there will be
physical beatings and that the neophytes can quit anytime they want. They were brought to
another house to commence their initiation.The neophytes were insulted and threatened even
before they got off the van. Members of the fraternity delivered blows to the neophytes as they
alighted from the van. Several initiation rites were experienced by the neophytes like the Indian
run, Bicol express and rounds. They were asked to recite provisions and principles of the
fraternity and were hit everytime they made a mistake. Accused fraternity members, Dizon and
Villareal, asked the head of the initiation rites (Victorino) to reopen the initiation. Fraternity
members subjected neophytes to paddling and additional hours of physical pain. After the last
session of beatings, Lenny Villa could not walk. Later that night, he was feeling cold and his
condition worsened. He was brought to the hospital but was declared dead on arrival. Criminal
case was filed against 26 fraternity members and was subsequently found guilty beyond
reasonable doubt of the crime of homicide and penalized with reclusion perpetua. On January 10
2002, CA modified the criminal liability of each of the accused according to individual
participation. 19 of the the accused were acquitted, 4 of the appellants were found guilty of slight
physical injuries, and 2 of the accused-appellants (Dizon and Villareal) were found guilty beyond
reasonable doubt of the crime of homicide. Accused Villareal petitioned for review on Certriori
under Rue 45 on the grounds that the CA made 2 reversible errors: first, denial of due process
and second, conviction absent proof beyond reasonable doubt. Consequently, petitioner Villareal
died on 13 March 2011 and filed a Notice of Death of Party on 10 August 2011.
ISSUE: Whether or not criminal liability for personal penalties of the accused is extinguished by
death
Doctrine: Yes, criminal liability of the accused is extinguished by death. The Court took note of
counsel for petitioners Notice of Death when it has been received while the petition was pending
resolution. Personal penalties refer to the service of personal or imprisonment penalties, while
pecuniary penalties refer to fines, costs, civil liability. Article 89 of the Revised Penal Code states
that the criminal liability of a convict for personal penalties is totally extinguished by death of
the convict. His pecuniary penalty has been extinguished since the death of the accused
happened before his final judgment. Therefore, the death of the petitioner for both personal and
pecuniary penalties including his civil liability has ended. His petition has also been dismissed
and the criminal case against him has been closed and terminated.