People v. Bunay
REITERATIONFacts
The Antecedents: The Regional Trial Court (RTC), Branch 26, in Luna, Apayao, convicted BRINGAS BUNAY y DAM-AT of qualified rape and sentenced him to suffer the Supreme Penalty of Death. The RTC also ordered the accused to pay civil indemnity, exemplary damages, and moral damages to the victim, "AAA". Procedural History: The conviction was brought for automatic review. The case was transferred to the Court of Appeals (CA) for intermediate review. The CA affirmed the conviction for qualified rape. Following the CA's denial of his motion for reconsideration, the accused appealed to the Supreme Court. The Petition: The accused appealed his conviction to the Supreme Court.
Issue(s)
Whether the death of the accused during the pendency of his appeal extinguishes his criminal liability. Whether the death of the accused during the pendency of his appeal extinguishes his civil liability.
Ruling
The appeal of the accused is dismissed, and the criminal case is considered closed and terminated.
Ratio Decidendi
On whether the death of the accused during the pendency of his appeal extinguishes his criminal liability: The Court held that the death of the accused during the pendency of his appeal, prior to the rendition of a final judgment, totally extinguished his criminal liability. This is in accordance with Article 89 of the Revised Penal Code, which 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 accused died on March 25, 2010, at the New Bilibid Prison Hospital, while his appeal was pending before the Supreme Court. No final judgment had yet been rendered at the time of his death. Consequently, his criminal liability was totally extinguished. On whether the death of the accused during the pendency of his appeal extinguishes his civil liability: The death of the accused also extinguished the civil liability that was based exclusively on the crime for which he was convicted (i.e., ex delicto). This is because a final judgment of conviction had not yet been rendered by the time of his death. Only civil liability predicated on a source of obligation other than the delict would survive the death of the accused, which the offended party could recover through a separate civil action. Therefore, the appeal was dismissed, and the case was considered closed and terminated.
Main Doctrine
The death of an accused during the pendency of their appeal, before final judgment, totally extinguishes both criminal and civil liability ex delicto.