People v. Brillantes
REITERATIONFacts
1. The Antecedents: The case involves charges against Saturnino de la Cruz and Jose Brillantes y Lopez for violations of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002. Specifically, De la Cruz was charged with illegal possession of 0.1 gram of shabu. Brillantes faced charges for the illegal sale of 0.1 gram of shabu and illegal possession of 2.6 grams of shabu. Both accused initially pleaded not guilty to the charges. 2. Procedural History: The Regional Trial Court (RTC) of Laoag City, Branch 13, found both De la Cruz and Brillantes guilty of the charges. The RTC sentenced De la Cruz to twelve (12) years and one (1) day to fifteen (15) years imprisonment and a fine of P300,000.00 for illegal possession. Brillantes was sentenced to life imprisonment and a P2,000,000.00 fine for illegal sale, and twelve (12) years and one (1) day to fifteen (15) years imprisonment and a P300,000.00 fine for illegal possession. The Court of Appeals affirmed the RTC's decision. Brillantes filed a Notice of Appeal to the Supreme Court, while De la Cruz did not appeal his conviction. 3. The Petition: Jose Brillantes y Lopez filed an appeal with the Supreme Court assailing the Court of Appeals' decision. However, while the appeal was pending, Brillantes died on January 3, 2012. The Supreme Court, therefore, resolved the effect of his death on his criminal and pecuniary liabilities. Citing Article 89(1) of the Revised Penal Code and the ruling in People v. Bayotas, the Court declared the appeal moot and academic, extinguishing both Brillantes' criminal and pecuniary liabilities due to his death prior to final judgment. The appeal of Brillantes did not affect the conviction of his co-accused, De la Cruz, who did not appeal.
Issue(s)
Whether the death of the accused-appellant pending appeal extinguishes his criminal and pecuniary liabilities. Whether the appeal of the accused-appellant affects the conviction of his co-accused who did not appeal.
Ruling
The appeal of Jose Brillantes y Lopez is declared moot and academic due to his death pending appeal. His criminal and pecuniary liabilities are extinguished. The conviction of his co-accused, Saturnino de la Cruz, remains unaffected.
Ratio Decidendi
On the extinguishment of criminal and pecuniary liabilities upon death pending appeal: 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. Pecuniary penalties are extinguished only when the death occurs before final judgment. In this case, Brillantes died while his appeal was pending, which means there was no final judgment yet. Therefore, both his personal penalty of imprisonment and pecuniary penalty of fine are extinguished. This principle is further elucidated in People v. Bayotas, which states that the death of the accused pending appeal of his conviction extinguishes his criminal liability and the civil liability based solely thereon. However, claims for civil liability may survive if they can be predicated on other sources of obligation besides delict, such as law, contracts, quasi-contracts, or quasi-delicts. In violations of RA 9165, there is no civil liability involved as no private offended party is present, and the trial court's decision did not refer to any civil liability. On the effect of the appeal on the co-accused: Rule 122, Section 11(a) of the Rules on Criminal Procedure states that an appeal taken by one or more of several accused shall not affect those who did not appeal, except insofar as the judgment of the appellate court is favorable and applicable to the latter. In this case, Brillantes' appeal resulted in the extinguishment of his liabilities due to his death, which is not an acquittal. Therefore, this outcome is not favorable or applicable to De la Cruz, who did not file an appeal. Consequently, De la Cruz's conviction remains valid and unaffected by Brillantes' appeal and subsequent death.
Main Doctrine
The death of an accused pending appeal of his conviction extinguishes both his criminal and pecuniary liabilities, rendering the appeal moot and academic. This extinguishment does not affect the conviction of co-accused who did not appeal.