People vs.

Dungo 199 SCRA 860

Rosalino Dungo stabbed Mrs. Sigua, with a knife from the envelope he was carrying, inside the
field office of the Department of Agrarian Reform. Mrs. Sigua died and an information for
murder was filed against Dungo. The accused raised the defense of insanity. During the trial, the
prosecution presented the victims husband, Atty. Sigua, to testify that the accused visited their
house to confront him on why his wife was making it difficult for the accused to transfer the
landholding his father to him. The trial court convicted him because the act of concealing a fatal
weapon and the act of taking flight in order to evade arrest indicates that accused was sane
during the time he committed the stabbing.

The case went up to the Supreme Court for automatic review.

Issue: Whether it is permissible to receive evidence of the accuseds mental condition for a
reasonable period both before and after the time of the act in question.

RULING:
Yes. The Court held that Evidence of insanity must have reference to the mental condition of
the person whose sanity is in issue, at the very time of doing the act which is the subject of
inquiry. However, it is permissible to receive evidence of his mental condition for a reasonable
period both before and after the time of the act in question. Direct testimony is not required
nor the specific acts of derangement essential to establish insanity as a defense.
Dungo v People (2015)

DANDY DUNGO and GREGORIO SIBAL, JR. vs. PEOPLE OF THE PHILIPPINES
G.R. No. 209464 July 1, 2015

Facts:

On January 14, 2006, at Villa Novaliches, Brgy. Pansol, Calamba City, Laguna, the Alpha Phi
Omega Fraternity in conspiracy with more or less twenty other members and officers conducted
initiation rite. MARLON VILLANUEVA y MEJILLA, a neophyte was subjected to physical
harm.
After the initiation rites, accused Sibal inquired about Villanueva's condition but he was ignored
by Castillo. He then called co-accused Dungo for help. After Dungo arrived at the resort, they
hailed a tricycle and brought Villanueva to JP Rizal Hospital. There, he gave a false name to the
security guard as he heard that Dungo had done the same.

RTC found Dungo and Sibal guilty of the crime of violating Section 4 of the Anti-Hazing Law
and sentenced them to suffer the penalty of reclusion perpetua.

The CA ruled that the appeal of Dungo and Sibal was bereft of merit.

Issue:

Whether or not herein accused were guilty of violation of R.A. No. 8049.

Ruling:
Yes, they are guilty of violation of R.A. No. 8049.

Section 1 of R.A. No. 8049 defines hazing as an initiation rite or practice as a prerequisite for
admission into membership in a fraternity, sorority or organization by placing the recruit,
neophyte or applicant in some embarrassing or humiliating situations such as forcing him to do
menial, silly, foolish and other similar tasks or activities or otherwise subjecting him to physical
or psychological suffering or injury. From the said definition, the elements of the crime of hazing
can be determined:
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 such as forcing him to do menial, silly, foolish and other similar tasks or activities or
otherwise subjecting him to physical or psychological suffering or injury.

Classes of direct participants are: the first class of principals would be the actual participants in
the hazing. If the person subjected to hazing or other forms of initiation rites suffers any physical
injury or dies as a result thereof, the officers and members of the fraternity, sorority or
organization who actually participated in the infliction of physical harm shall be liable as
principals. The second class of principals would be the officers, former officers, or alumni of the
organization, group, fraternity or sorority who actually planned the hazing. The third class of
principals would be the officers or members of an organization group, fraternity or sorority who
knowingly cooperated in carrying out the hazing by inducing the victim to be present thereat due
to their indispensable cooperation in the crime by inducing the victim to attend the hazing. The
next class of principals would be the fraternity or sorority's adviser. The last class of principals
would be the parents of the officers or members of the fraternity, group, or organization.

Exceptionally, under R.A. No. 8049, the participation of the offenders in the criminal conspiracy
can be proven by the prima facie evidence due to their presence during the hazing, unless they
prevented the commission of the acts therein.

(SOURCE: PALS 2016, Prepared by: Dean Gemy Lito L. Festin and the students of Polytechnic
University of the Philippines)
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANCISCO CAGOCO Y
RAMONES,defendant-appellant
GR No. L-38511October 6, 1933
VICKERS, J.

FACTS
On July 24, 1932, Manila, the accused willfully, unlawfully, feloniously, without any just cause therefor and with
intent to kill and treachery, assaulted and attacked Yu Lon by suddenly giving him a fist blow on the back part of
the head, treacherously, under conditions which intended directly and especially to insure, the accomplishment of
his purpose without risk to himself arising from any defense the victim Yu Lon might make, thus causing him to
fall on the ground as a consequence of which he suffered a lacerated wound in the scalp and a fissured fracture on
the left occipital region, which were necessarily mortal and which caused the immediate death of the said Yu Lon.
Defendant was found guilty of murder in the CFI, for which the defendant made an appeal.

ISSUE
W/N a naturally resulting injury from a direct consequence of an unlawful act would make the aggressor
criminally liable

DECISION

APPELLATE COURT
J. Vickers.
Regarding the contention of the appellant that striking Yu Lon at the back of the head would not possibly cause
him to fall forward on his face to the pavement, the Court declared that the expert testimony shows that the
victim had undergone a natural phenomenon of falling backwards on the pavement in an attempt to regain
balance. Another consideration was the slope of the sidewalk, which could have made Yu Lon fall the opposite
direction from which he was struck, as he tried to straighten up. The Court referred to paragraph 1, Article 4 of the
RPC which provides that criminal liability shall be incurred by any person committing a felony (delito) although
the wrongful act done be different from what he intended; but in order that a person be criminally liable, the
following requisites must be present: (1) that a felony was (1) that a felony was committed, and (2) that the wrong
done tothe aggrieved person be the direct consequence of the crime committed by the offender. There is no doubt
as to the cause of the death of Yu Lon, which occurred as the direct consequence of the blow dealt by the appellant,
and the fact that the defendant did not intend to cause so great an injury does not relieve him from the consequence
of his unlawful act.