People v. Sumaya
REITERATIONFacts
1. The Antecedents: Accused-appellant Gregorio Sumaya y Dalogdog was charged with rape and attempted rape in four separate informations before the Regional Trial Court of Iligan City. 2. Procedural History: Following a plea of not guilty, the trial court found the accused guilty of the charges. The accused then appealed his conviction to the Supreme Court. During the pendency of the appeal, the accused-appellant died. 3. The Petition: The appeal was dismissed by the Supreme Court following the death of the accused-appellant. The Court cited precedent holding that the death of an accused pending appeal extinguishes both the criminal and the civil liability ex delicto, as there is no longer a defendant to stand as the accused and the civil action is grounded on the criminal.
Issue(s)
Whether the death of the accused-appellant pending appeal extinguishes his criminal and civil liability. Whether the appeal should be dismissed.
Ruling
The Court dismissed the appeal of the late Gregorio Sumaya, declaring the case closed and terminated. The Court held that the death of the accused-appellant pending appeal extinguished both his criminal and civil liability ex delicto.
Ratio Decidendi
On the issue of extinguishment of criminal and civil liability: The Court, citing People vs. Rogelio Bayotas, held that upon the death of the accused pending appeal of his conviction, the criminal action is extinguished because there is no longer a defendant to stand as the accused. Consequently, the civil action instituted therein for the recovery of civil liability ex delicto is ipso facto extinguished, as it is grounded on the criminal action. The records did not disclose any civil liability arising from other sources such as contract, quasi-contract, quasi-delict, or law. Therefore, the appeal was dismissed as the case was declared closed and terminated. On the dismissal of the appeal: Given that the accused-appellant had died and his criminal and civil liabilities ex delicto were extinguished, there was no longer a live case to be resolved on its merits. The appeal was thus dismissed.
Main Doctrine
The death of an accused pending appeal of his conviction extinguishes both the criminal and the civil liability ex delicto, as there is no longer a defendant to stand trial and the civil action is grounded on the criminal action.