People v. Albofera
REVERSALFacts
The Antecedents: Accused-appellants Alexander Albofera and Romeo Lawi-an were convicted of Murder. This Court, in a Decision promulgated on July 20, 1987, affirmed their conviction, commuting the penalty from death to reclusion perpetua and fixing civil liability at P30,000.00. Procedural History: On September 3, 1987, de officio counsel for the accused-appellants filed a Manifestation and Motion for Reconsideration, praying for dismissal of the case or appeal due to the supervening development of an absolute pardon granted by the President of the Philippines. The Petition: The Solicitor General manifested that the accused-appellants were indeed granted absolute pardon on January 29, 1987, which extinguished their criminal liability but not their civil liability. The motion for reconsideration was filed to reflect this supervening event.
Issue(s)
Whether the absolute pardon granted to the accused-appellants is valid and effective. Whether the absolute pardon extinguishes criminal liability, and whether it also extinguishes civil liabilities.
Ruling
The Motion for Reconsideration is partially granted. The accused-appellants shall no longer suffer the penalty of reclusion perpetua but shall still indemnify the heirs of the victim, Teodoro Carancio, in the amount of P30,000.00, and shall each pay one-half (1/2) of the costs.
Ratio Decidendi
On the validity and effectivity of the absolute pardon: The Court held that the absolute pardon granted by the President on January 29, 1987, was valid, binding, and effective. This was because the pardon was extended prior to the effectivity of the 1987 Constitution on February 2, 1987, at which time there was no requirement that pardon could only be extended after conviction by final judgment. Therefore, the pardon validly extinguished the criminal liability of the accused-appellants. On the extinguishment of criminal versus civil liabilities: The Court clarified that while an absolute pardon extinguishes criminal liability, it does not, in any case, exempt the culprit from the payment of the civil indemnity imposed upon him by the sentence. This is explicitly provided for in Article 36 of the Revised Penal Code. Consequently, despite the pardon, the civil liability of the accused-appellants to indemnify the heirs of the victim remained.
Main Doctrine
An absolute pardon granted by the President extinguishes criminal liability but does not exempt the culprit from the payment of civil indemnity imposed by the sentence.