Hazing, Honor, and the Price of Tradition: The Court Ruling that Echoes Through PMA

By Louis ‘Barok‘ C. Biraogo

IN THE crisp air of Baguio, a place often associated with peace and retreat, a different kind of storm was brewing. It wasn’t the typhoon season that gripped the city, but the aftermath of a harrowing revelation that shook the foundations of one of the Philippines’ most prestigious institutions. On September 18, 2019, the nation was forced to confront a brutal tradition hidden within the hallowed halls of the Philippine Military Academy (PMA). The death of Cadet 4th Class Darwin Dormitorio, a 20-year-old with a future as bright as the stars on his uniform, became the face of an enduring culture of violence—hazing.

The Shadow of Tradition

Hazing at the PMA is not a new phenomenon. Since the academy’s inception in 1936, it has been plagued by a deeply entrenched culture of physical and psychological abuse, often justified under the guise of building discipline and camaraderie. The tradition of “katay,” a disavowed yet persistent practice, allowed senior cadets to “discipline” their juniors, resulting in countless cases of physical abuse. The academy, which has produced the country’s top military officers, also became a breeding ground for practices that led to injuries, trauma, and, tragically, deaths.

Despite efforts to curb this dark tradition, the veil of secrecy and the culture of silence persisted. For decades, stories of abuse rarely made it past the academy’s gates. The unspoken rule was clear: what happens in the barracks stays in the barracks. But in 2019, the PMA’s walls could no longer contain the truth.

The Death of Darwin Dormitorio

Darwin Dormitorio’s death was not just another statistic; it was a catalyst for change. His last hours were filled with unimaginable pain—a torment that no soldier, let alone a cadet in training, should ever endure. His body bore the marks of repeated assaults: bruises on his chest, stomach, and back—a grim testament to the abuse he suffered at the hands of his fellow cadets. The official diagnosis—cardiopulmonary arrest secondary to blunt thoracoabdominal injury—painted a chilling picture of his final moments.

In the days leading up to his death, Darwin had reported being subjected to brutal physical exercises and beatings by his upperclassmen. It was later revealed that he, along with other plebes, had endured electrocution by taser—a sickening form of torture that harkened back to the medieval practices. Darwin’s death was the culmination of a month-long cycle of abuse, a tragic end to a life that had barely begun.

The Court’s Verdict: A Moment of Reckoning

The Baguio Regional Trial Court (RTC) Branch 5’s decision on August 16, 2024, marked a significant turning point in the fight against hazing. In a landmark ruling, the court found two cadets, Shalimar Imperial Jr. and Felix Lumbag Jr., guilty of murder and violating the Anti-Hazing Act of 2018. Both were sentenced to reclusion perpetua, a sentence that carries a weighty 40 years of imprisonment, the maximum penalty under Philippine law. In addition, they were ordered to pay substantial fines and damages to Darwin’s family—a small but symbolic measure of justice for the immense loss they endured.

A third cadet, Julius Carlo Tadena, was found guilty of violating the Anti-Hazing Act and received a similar sentence. His conviction was a stern reminder that participation in hazing, regardless of intent, bears consequences.

The court’s decision was not merely a legal victory; it was a moral stance against a culture that had claimed too many lives. The verdict sent a clear message: the era of impunity for hazing at the PMA was over.

Legal Framework: Statutes and Case Law

The court’s ruling was grounded in the Anti-Hazing Act of 2018, a law designed to curb the pernicious practice that had taken root in many institutions, not just the PMA. The law is clear and uncompromising: it holds individuals accountable for hazing-related deaths, with penalties that include life imprisonment and hefty fines. The Baguio RTC’s application of this law underscored its commitment to upholding justice, ensuring that the perpetrators of this heinous crime were held accountable.

Historically, the Philippine Supreme Court has also taken a strong stance against hazing. In the landmark case of People v. Dionisio (G.R. No. 163856, July 27, 2007), the Court affirmed the conviction of individuals involved in hazing, reiterating that the physical and psychological trauma inflicted upon victims constitutes a grave violation of their rights. This precedent, along with others, provided a solid legal foundation for the RTC’s decision in the Dormitorio case.

The Defense: A Struggle Against Tradition

The accused, through their defense, attempted to invoke the institutional traditions of the PMA, arguing that hazing was an ingrained part of the academy’s culture—a misguided rite of passage. They contended that the practices, though harsh, were meant to instill discipline and resilience, essential qualities for future military leaders. However, this defense crumbled in the face of overwhelming evidence and the clear provisions of the Anti-Hazing Act, which categorically outlawed such practices.

Philippine law does not provide sanctuary for those who hide behind tradition to justify acts of violence. The Supreme Court, in cases such as People v. Banogon (G.R. No. 128800, June 21, 2000), has repeatedly emphasized that cultural or institutional practices cannot override the law. The RTC’s rejection of the defense’s arguments was a reaffirmation of this principle, signaling that the law would not be swayed by appeals to tradition when lives are at stake.

The Road Ahead: Legal Options and Recommendations

For the accused, the legal battle is far from over. They retain the right to appeal the RTC’s decision to the Court of Appeals, and potentially, the Supreme Court. In doing so, they may seek to challenge the interpretation of the Anti-Hazing Act or the application of the murder charge. However, given the strength of the evidence and the precedents set by previous rulings, their chances of overturning the conviction appear slim.

For Darwin Dormitorio’s family, the verdict provides a measure of closure, but it does not erase the pain of their loss. Their journey towards healing continues, and the fight against hazing must persist.

A Call to Action: Eradicating Hazing for Good

The Dormitorio case has cast a long shadow over the PMA, but it also presents an opportunity for profound change. The academy must take this moment to recommit to its values—honor, duty, and loyalty—by eradicating the toxic elements of its culture that have allowed hazing to thrive. This includes not only enforcing the Anti-Hazing Act with greater vigilance but also fostering an environment where respect and dignity are paramount.

The government, too, has a role to play. Legislators and law enforcement agencies must ensure that the Anti-Hazing Act is rigorously implemented across all institutions. The Department of National Defense should oversee reforms within the PMA, ensuring that cadet training is rigorous yet humane, free from the shadow of violence.

Hazing is not a test of strength or endurance—it is a cowardly act that preys on the vulnerable. The tragic death of Darwin Dormitorio is a stark reminder that tradition cannot justify brutality. As the nation reflects on this case, it must ask itself: How many more lives must be lost before we say enough? The time for change is now, and it begins with justice for Darwin.