People v. Dionaldo
REITERATIONFacts
1. The Antecedents: The case involves accused-appellants Armando Dionaldo y Ebron, Renato Dionaldo y Ebron, Mariano Gariguez, Jr. y Ramos, and Rodolfo Larido y Ebron, who were charged with the special complex crime of Kidnapping for Ransom with Homicide. 2. Procedural History: The Court of Appeals affirmed the decision of the Regional Trial Court finding the accused-appellants guilty. Subsequently, the Supreme Court, in a Resolution dated July 23, 2014, dismissed their appeal and affirmed the Court of Appeals' decision, sentencing them to reclusion perpetua. The accused-appellants moved for reconsideration, which was denied by the Court on September 24, 2014. 3. The Petition: This resolution addresses a letter from the Bureau of Corrections informing the Court of the death of accused-appellant Renato Dionaldo y Ebron on June 10, 2014, prior to the promulgation of the Supreme Court's July 23, 2014 Resolution. Citing Article 89 of the Revised Penal Code and jurisprudence, the Court recognized that Renato's death extinguished his criminal liability. Consequently, the Court set aside its previous resolutions and dismissed the case against Renato Dionaldo y Ebron.
Issue(s)
Whether the criminal liability of Renato Dionaldo y Ebron is extinguished by his death pending appeal, including its effect on personal penalties, pecuniary penalties, and civil liability ex delicto. Whether the Resolutions dated July 23, 2014 and September 24, 2014 are rendered ineffectual as to Renato Dionaldo y Ebron, considering his death before the promulgation of the Court's Resolution.
Ruling
The Resolutions dated July 23, 2014 and September 24, 2014 are set aside insofar as accused-appellant Renato Dionaldo y Ebron is concerned. Criminal Case No. C-68329 before the Regional Trial Court of Caloocan City, Branch 129 is dismissed with respect to Renato Dionaldo y Ebron due to his demise.
Ratio Decidendi
On the extinguishment of criminal liability by death: The Court reiterated the principle that the death of an accused pending appeal of their conviction totally extinguishes their criminal liability. This is in accordance with Article 89 of the Revised Penal Code, which enumerates the modes by which criminal liability is totally extinguished. The death of the convict extinguishes personal penalties, and pecuniary penalties are extinguished only if death occurs before final judgment. In this case, Renato Dionaldo y Ebron died on June 10, 2014, before the promulgation of the Court's Resolution on July 23, 2014, which was still pending appeal. Therefore, his criminal liability is totally extinguished. The Court further clarified that the death of the accused pending appeal also extinguishes their civil liability ex delicto. This means that any pecuniary obligations arising directly from the offense committed are also terminated upon the offender's death before final judgment. Therefore, the monetary awards ordered in the July 23, 2014 Resolution are also rendered ineffectual as to Renato Dionaldo y Ebron. On the effect of death on the appeal: Consequently, Renato's death renders the Court's July 23, 2014 Resolution irrelevant and ineffectual as to him. The appeal, which was pending resolution before the Supreme Court at the time of his death, can no longer be validly decided against him. The Court's pronouncements regarding his guilt and the imposed penalties are thus set aside concerning Renato. The criminal case against him is dismissed.
Main Doctrine
The death of an accused pending appeal of their conviction extinguishes both criminal and civil liability ex delicto, rendering the resolution of the appeal moot as to the deceased accused.