People v. Dimaala
REITERATIONFacts
The Antecedents: Accused-appellant Agapito Dimaala y Arela was found guilty beyond reasonable doubt by the Regional Trial Court (RTC) of Calauag, Quezon, for the crime of Murder, specifically the treacherous killing of Rodrigo Marasigan. The RTC sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, actual damages, exemplary damages, and temperate damages. Procedural History: Accused-appellant appealed his conviction to the Court of Appeals (CA). The CA affirmed the RTC's decision but deleted the award of temperate damages. Accused-appellant then filed a Notice of Appeal before the Supreme Court but subsequently filed a Motion to Withdraw Appeal, which was granted, leading to the entry of judgment. The Petition: The Supreme Court received a letter from the Bureau of Corrections informing it of the death of accused-appellant Agapito Dimaala y Arela on August 23, 2016, at the New Bilibid Prison Hospital, evidenced by a Certificate of Death. This development occurred after the CA decision and after the accused-appellant withdrew his appeal to the Supreme Court but before the finality of judgment in the Supreme Court.
Issue(s)
Whether the death of the accused-appellant prior to final judgment extinguishes the criminal action and the civil action for the recovery of civil liability ex delicto. Whether civil liability based on sources other than the delict survives the death of the accused.
Ruling
The Court resolved to DISMISS Crim. Case No. 4994-C and DECLARE the instant case CLOSED and TERMINATED by reason of the death of accused-appellant Agapito Dimaala y Arela.
Ratio Decidendi
On the extinguishment of criminal and civil liability ex delicto: The Court reiterated the settled rule that the death of an accused prior to final conviction by the Supreme Court renders the criminal case dismissible. Article 89(1) of the Revised Penal Code explicitly provides that criminal liability is totally extinguished by the death of the convict as to personal penalties, and as to pecuniary penalties, liability is extinguished only when the death occurs before final judgment. In this case, the accused-appellant died while his appeal was pending before the Supreme Court, and before a final judgment was rendered by this Court. Therefore, his criminal liability is extinguished. Furthermore, the civil liability directly arising from and based solely on the offense committed, known as civil liability ex delicto, is also extinguished by his death before final judgment. This principle was affirmed in jurisprudence, citing cases that explain the effects of the death of an accused pending appeal. On the survival of civil liability from other sources: The Court clarified that while civil liability ex delicto is extinguished, the claim for civil liability may survive if it can be predicated on a source of obligation other than the delict itself. This means that if the victim's claim for damages arises from other legal grounds, such as quasi-delict or contract, or if there are other obligations of the deceased not directly tied to the commission of the crime, these liabilities are not automatically extinguished. The victim may still pursue a separate civil action against the estate of the accused-appellant to recover such damages, as may be warranted by law and procedural rules. The Court stressed that the extinguishment pertains only to the civil liability directly and solely arising from the crime charged.
Main Doctrine
The death of an accused prior to final judgment extinguishes both criminal liability and civil liability ex delicto. However, civil liability based on other sources of obligation survives and may be pursued separately against the estate of the deceased.