People v. Morales
REITERATIONFacts
The Antecedents: Accused-appellant Alfredo Morales y Lam (Morales) was charged with illegal sale of shabu in Criminal Case No. 7534 and illegal possession of shabu in Criminal Case No. 7535, both in violation of Republic Act No. 9165. The charges stemmed from an incident on April 14, 2004, in Rodriguez, Rizal. Procedural History: The Regional Trial Court (RTC) of San Mateo, Rizal, Branch 76, found Morales guilty beyond reasonable doubt for both offenses. The RTC relied on the categorical statements of prosecution witnesses against the bare denials of the accused and upheld the presumption of regularity in the performance of duties by law enforcement officers. Upon appeal, the Court of Appeals affirmed the RTC's decision, upholding the presence of all elements of the offenses and the preservation of the corpus delicti. The appellate court liberally construed the procedural steps required by Section 21 of RA 9165 in favor of the prosecution and affirmed the presumption of regularity. The Petition: Morales filed a Notice of Appeal before the Supreme Court assailing the Court of Appeals' decision.
Issue(s)
Whether the accused-appellant was guilty beyond reasonable doubt of illegal sale and illegal possession of dangerous drugs. Whether the appeal should be dismissed due to the death of the accused-appellant pending appeal.
Ruling
The appeal was declared moot and academic due to the death of the accused-appellant pending appeal. The Court noted that the death of the accused-appellant extinguishes both his criminal and civil liabilities. Since a violation of Republic Act No. 9165 does not entail civil liability, there is no civil liability to be extinguished. Therefore, the appeal from the decision of the Court of Appeals is rendered moot and academic.
Ratio Decidendi
On the guilt of the accused-appellant: The RTC and the Court of Appeals found Morales guilty beyond reasonable doubt for illegal sale and illegal possession of dangerous drugs. The appellate court upheld the presence of all the elements of the offenses and the preservation of the corpus delicti. The procedural steps required by Section 21 of Republic Act No. 9165 were liberally construed in favor of the prosecution. The presumption of regularity of performance of duties by the police officers was affirmed in the absence of any showing of ill-motive. On the effect of the death of the accused-appellant pending appeal: The Court took judicial notice of the death of accused-appellant Alfredo Morales y Lam on November 2, 2013, while his case was pending appeal. Under Article 89(1) of the Revised Penal Code, criminal liability is totally extinguished by the death of the convict. Pecuniary liabilities are extinguished only when the death occurs before final judgment. However, the Court clarified that a violation of Republic Act No. 9165 does not entail any civil liability, thus, no civil liability needs extinguishment. Consequently, the appeal was declared moot and academic.
Main Doctrine
The death of an accused pending appeal of a conviction for violations of Republic Act No. 9165 extinguishes both criminal and civil liabilities, rendering the appeal moot and academic, as RA 9165 does not entail civil liability.