People v. Ayochok
REITERATIONFacts
The Antecedents Jaime Ayochok y Tauli was charged with Murder for allegedly shooting SPO1 Claudio Caligtan y Ngodo multiple times while the victim was relieving himself. The prosecution alleged that the killing was committed with evident premeditation, treachery, and cruelty, resulting in the victim's death due to hypovolemic shock from massive hemorrhage and multiple gunshot wounds. Procedural History The Regional Trial Court (RTC) of Baguio City, Branch 6, found Ayochok guilty of Murder and sentenced him to reclusion perpetua, along with substantial civil indemnities. This decision was affirmed with modifications by the Court of Appeals. Initially, the case was automatically elevated to the Supreme Court, but following the People v. Mateo ruling, it was transferred to the Court of Appeals, where it was docketed as CA-G.R. CR No. 00949. After the Court of Appeals affirmed the conviction, Ayochok filed a notice of appeal to the Supreme Court, which was docketed as G.R. No. 175784. The Petition The appeal to the Supreme Court, docketed as G.R. No. 175784, was filed by Jaime Ayochok y Tauli, seeking to overturn the decision of the Court of Appeals. However, during the pendency of the appeal, Ayochok died. The Supreme Court, citing Article 89(1) of the Revised Penal Code and the ruling in People v. Bayotas, determined that the death of the accused-appellant extinguished both his criminal liability and his civil liability ex delicto. Consequently, the Court set aside the Court of Appeals' decision and dismissed the case.
Issue(s)
Whether the death of the accused-appellant pending appeal extinguishes his criminal and civil liabilities. Whether the appealed decision of the Court of Appeals remains valid and enforceable in light of the accused-appellant's death.
Ruling
The Supreme Court set aside the decision of the Court of Appeals and dismissed the criminal case due to the death of the accused-appellant pending his appeal. Costs were ordered de officio.
Ratio Decidendi
On the issue of the effect of the accused-appellant's death pending appeal: Applying Article 89(1) of the Revised Penal Code and the guidelines laid down in People v. Bayotas, the Court held that the death of the accused-appellant during the pendency of his appeal extinguishes not only his criminal liability but also his civil liability solely arising from or based on the crime committed (civil liability ex delicto). The Court clarified that if the civil liability could be predicated on other sources of obligation such as law, contracts, quasi-contracts, or quasi-delicts, then the claim for civil liability would survive and could be pursued through a separate civil action against the executor or administrator of the estate. However, in this case, the civil liability was solely based on the crime of murder. On the validity and enforceability of the appealed decision: Given that the accused-appellant's death extinguished both his criminal and civil liabilities ex delicto, the appealed decision of the Court of Appeals, which found Ayochok guilty of Murder, sentenced him to imprisonment, and ordered him to indemnify his victim, had become ineffectual. The Court found it unnecessary to rule on the merits of Ayochok's appeal, as the supervening event of his death rendered the question of his guilt irrelevant. Consequently, the case was dismissed. The Court noted that Ayochok's appeal was still pending and no final judgment of conviction had been rendered against him when he died. This procedural posture, coupled with the extinguishment of his liabilities, led to the dismissal of the case. The Court reiterated the principle that death pending appeal terminates criminal liability and civil liability ex delicto prior to final judgment, as established in People v. Bayotas.
Main Doctrine
The death of the accused pending appeal of his conviction extinguishes both his criminal liability and the civil liability solely arising from or based on the crime committed (civil liability ex delicto).