People v. Alison
REITERATIONFacts
The Antecedents: The underlying dispute involved a charge of robbery in band with double murder and attempted murder against several defendants, including Bonifacio Alison. The Court of First Instance of Quezon, Branch IV, had sentenced these defendants, including Bonifacio Alison, to life imprisonment. Procedural History: Following the conviction by the Court of First Instance of Quezon, Branch IV, the case proceeded on appeal to the Supreme Court. During the pendency of this appeal, a communication was received from the Administrative Officer of the Bureau of Prisons informing the Court of the death of prisoner Bonifacio Alison on January 26, 1972, due to Pulmonary Tuberculosis. The Petition: While not a formal petition for review, the Supreme Court, upon receiving notification of Bonifacio Alison's death, issued a resolution requiring the Solicitor General to comment. The Solicitor General subsequently confirmed the death and argued that, in accordance with Article 89 of the Revised Penal Code and prevailing jurisprudence, both the criminal and civil liability of the deceased appellant were extinguished. Therefore, the case against Bonifacio Alison should be dismissed.
Issue(s)
Whether the criminal and civil liability of an accused-appellant is extinguished by his death during the pendency of his appeal. Whether the case against the deceased accused-appellant should be dismissed.
Ruling
The case against the late Bonifacio Alison is dismissed with costs de oficio.
Ratio Decidendi
On Whether the criminal and civil liability of an accused-appellant is extinguished by his death during the pendency of his appeal: The Court held that the death of accused-appellant Bonifacio Alison, having been established, and considering that there was as yet no final judgment in view of the pendency of the appeal, his criminal and civil liability was extinguished by his death. This is in accordance with Article 89 of the Revised Penal Code, which provides for the extinguishment of criminal liability by the death of the offender. The civil liability arising from the crime is also extinguished by the death of the accused before final judgment, as it is based on the criminal liability. The ruling in People vs. Castillo and Ofemia (C.A., 56 O.G. 4045) was cited in support of this principle. The death of the accused prior to the final judgment renders the appeal moot and academic concerning the accused. On Whether the case against the deceased accused-appellant should be dismissed: Consequently, the Court ordered the dismissal of the case against the late Bonifacio Alison. The Solicitor General, in his comment, recommended the dismissal of the case against the deceased appellant, citing Article 89 of the Revised Penal Code and jurisprudence. The Court adopted this recommendation, thereby terminating the proceedings against the deceased appellant.
Main Doctrine
The death of an accused-appellant before final judgment extinguishes both his criminal and civil liability, leading to the dismissal of the case against him.