De Guzman v. People
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns an accusation of theft against Ma. Lourdes R. de Guzman. The Information filed alleged that on or about February 8, 1995, in Makati City, the petitioner willfully, unlawfully, and feloniously, with intent of gain and without the owner's consent, took, stole, and carried away several pieces of jewelry valued at P4,600,000.00, belonging to Jasmine Gongora, causing damage and prejudice to the owner. 2. Procedural History: The Regional Trial Court, Branch 145, Makati City, in Criminal Case No. 96-1226, found Ma. Lourdes R. de Guzman guilty of theft on December 11, 1997, sentencing her to an indeterminate penalty and ordering her to pay civil damages. On appeal, the Court of Appeals affirmed the conviction with modification, reducing the award for actual damages to P1,500,000 and moral damages to P100,000, while deleting the award for attorney's fees. 3. The Petition: The petitioner filed a petition for review under Rule 45 of the Rules of Court, assailing the decision of the Court of Appeals. The petition raised issues regarding the alleged bias of the trial judge and the contention that the judgment of conviction was not proven beyond reasonable doubt. Subsequently, counsel for the petitioner informed the Court that the petitioner had passed away on January 13, 2003, from a vehicular accident, raising the issue of the effect of her death on the pending petition.
Issue(s)
Whether the death of the petitioner pending appeal affects the criminal liability. Whether the death of the petitioner pending appeal affects the civil liabilities; and whether the criminal and civil actions are extinguished by the death of the accused before final judgment.
Ruling
The Supreme Court denied the petition for review and set aside the appealed decision in view of the death of the petitioner. Costs de oficio.
Ratio Decidendi
On the issue of the effect of the petitioner's death on the criminal liability: The Court held that the death of the petitioner pending her appeal of a conviction extinguishes her criminal liability. Article 89(1) of the Revised Penal Code provides that criminal liability is totally extinguished by the death of the convict as to personal penalties. Furthermore, pecuniary penalties are extinguished only when the death of the offender occurs before final judgment. In this case, the judgment of conviction was pending review by the Supreme Court and had not yet attained finality. On the issue of the effect of the petitioner's death on the civil liabilities and the extinguishment of criminal and civil actions: Citing the case of People v. Bayotas, the Court reiterated that upon the death of the accused pending appeal of his conviction, the criminal action is extinguished. 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 pecuniary liabilities adjudged against the petitioner, namely actual damages representing the value of the stolen jewelry and moral damages, were undeniably ex delicto as they arose from the crime of Theft. Therefore, with the extinction of the criminal action, the civil liability attendant to the crime is also extinguished. A substitution of heirs is not necessary in such a scenario.
Main Doctrine
The death of the accused pending appeal of a conviction extinguishes both the criminal and civil liability ex delicto, as the criminal action is ipso facto extinguished, and the civil action is grounded on the criminal.