People v. Soria
REITERATIONFacts
The Antecedents: The Supreme Court rendered a Decision on November 14, 2012, finding accused-appellant Benjamin Soria y Gomez guilty beyond reasonable doubt of rape and sentencing him to twelve (12) years of prision mayor, as minimum, to twenty (20) years of reclusion temporal, as maximum. He was also ordered to pay damages to "AAA". The Decision was to become final and executory on December 20, 2012. Procedural History: The Bureau of Corrections informed the Supreme Court of the death of accused-appellant Benjamin Soria y Gomez on August 16, 2012. A certified true copy of his death certificate was submitted. The Petition: The Supreme Court was prompted to issue a Resolution to address the implications of the accused-appellant's death.
Issue(s)
Whether the death of the accused-appellant before the finality of the Supreme Court's decision extinguishes his criminal and civil liability. Whether the Supreme Court's Decision dated November 14, 2012, finding the accused-appellant guilty of rape, remains relevant and effectual.
Ruling
The Supreme Court set aside its November 14, 2012 Decision and dismissed the criminal case against Benjamin Soria y Gomez on account of his demise.
Ratio Decidendi
On whether the death of the accused-appellant before the finality of the Supreme Court's decision extinguishes his criminal and civil liability: Article 89 of the Revised Penal Code provides that criminal liability is totally extinguished by the death of the convict as to personal penalties. As to pecuniary penalties, liability is extinguished only when the death of the offender occurs before final judgment. In the case of People v. Amistoso, the Court clarified that the death of an accused pending appeal of his conviction extinguishes his criminal liability, as well as his civil liability ex delicto. Since the criminal action is extinguished due to the absence of a defendant, the civil action instituted therein for recovery of civil liability ex delicto is ipso facto extinguished, as it is grounded on the criminal case. The accused-appellant's death on August 16, 2012, occurred before the promulgation of the Supreme Court's Decision on November 14, 2012, and thus before its finality. Therefore, his appeal was still pending resolution when he died, leading to the extinguishment of his criminal and civil liabilities. On whether the Supreme Court's Decision dated November 14, 2012, finding the accused-appellant guilty of rape, remains relevant and effectual: By reason of the accused-appellant's death on August 16, 2012, the Supreme Court's Decision dated November 14, 2012, finding him guilty beyond reasonable doubt of rape, became irrelevant and ineffectual. Similar to the situation in People v. Amistoso, where the Court's decision affirming a conviction was rendered irrelevant and ineffectual by the accused's death prior to its finality, the same principle applies here. The Court had the jurisdiction to set aside its previous decision because it had not yet become final. Consequently, the case against the accused-appellant must be dismissed.
Main Doctrine
The death of an accused pending appeal of his conviction extinguishes both his criminal and civil liability ex delicto, rendering any subsequent decision by the appellate court irrelevant and ineffectual.