Fuertes vs Senate
G.R. No. 208162
Facts:
Devie Ann Isaga Fuertes (Fuertes) is among the 46 accused charged with violating the Anti-Hazing Law, or Republic Act No. 8049, for the death of Chester Paolo Abracia due to injuries he allegedly sustained during the initiation rites of the Tau Gamma Phi Fraternity.
Fuertes, a member of Tau Gamma Sigma Sorority, admitted that she was at the premises during the initiation rites. She was then 17 years old and was a student at that time.
Petitioner claims that Sections 3 and 4 of the Anti-Hazing Law are unconstitutional, as they would allow for the conviction of persons for a crime committed by others, in violation of the res inter alios acta rule. She also argues that these provisions violate Article III, Sections 1 and 19 of the Constitution for constituting a cruel and unusual punishment, as she was charged as a principal, and penalized with reclusion perpetua, for a non-bailable offense.
Issue:
Whether or not Sections 3 and 4 of the Anti-Hazing Law are unconstitutional.
Held:
No. Section 14, paragraph 4 of the Anti-Hazing Law, which provides that an accused's presence during a hazing is prima facie evidence of his or her participation, does not violate the constitutional presumption of innocence. This disputable presumption is also not a bill of attainder.
The constitutional presumption of innocence is not violated when there is a logical connection between the fact proved and the ultimate fact presumed. When such prima facie evidence is unexplained or not contradicted by the accused, the conviction founded on such evidence will be valid. However, the prosecution must still prove the guilt of the accused beyond reasonable doubt. The existence of a disputable presumption does not preclude the presentation of contrary evidence.