CA junks bid to dismiss Atio hazing case

The Court of Appeals (CA) has junked the petition of one of the suspects in the hazing death of Horacio “Atio” Castillo III to overturn the order of the Manila Regional Trial Court (RTC) to continue the trial.

The appellate court was petitioned by Ralph Trangia to reverse the Manila RTC’s decision denying his demurrer to evidence, arguing that it violated his due process rights and committed grave abuse of discretion when it did not grant his plea for acquittal.

In its ruling, the RTC said the prosecution was able to establish the elements of the crime of hazing and the presence of Trangia and his co-accused during the incident, and that witness Anthony Ventura, a fellow Aegis Juris fraternity member, was credible.

The CA Eighth Division, in its 25 April 2024 decision, ruled against Trangia, saying the Manila RTC was able to show the factual circumstances that it had used as basis for its orders denying his demurrer to evidence.

“Here, RTC-11, through the pieces of evidence presented by the prosecution, was able to determine that there is sufficient evidence to show that Horacio died of hazing and all the accused, including Trangia, were present during the commission of the crime,” said the decision penned by Associate Justice Jaime Fortunato Caringal.

In denying Trangia’s demurrer to evidence, the Manila RTC had found Ventura’s testimony to be credible because he was present during the hazing rights and was able to narrate the circumstances surrounding Castillo’s death.

Also, the Manila RTC assessed the credibility of Trangia’s witness, and found that the latter only relied on secondhand information, the CA said.

As such, it said the Manila RTC adequately stated the facts and the law that it used as basis for its orders.

The CA added, “This was even bolstered by the fact that Trangia was able to assign specific errors or grounds against the assailed Orders and discuss them intelligently. Trangia cannot now feign ignorance that he was unable to understand the basis of the assailed Orders.” 

The petition of Trangia, the CA also said. raised issues concerning alleged errors of judgment that are beyond the scope of the petition for certiorari that he had filed.

The CA said that it cannot review alleged errors in the appreciation of the prosecution’s evidence absent any showing of grave abuse of discretion on the part of the trial court when it issued its orders.

It said, “Here, Trangia failed to demonstrate acts and circumstances that exhibit grave abuse of discretion amounting to lack or excess of jurisdiction on the part of RTC-11.” 

“At the risk of being repetitive, a special civil action of certiorari does not include the correction of RTC-11’s evaluation of the evidence and factual findings thereon,” it added.