People v. Monroyo
REVERSALFacts
The Antecedents: Accused-appellant Norieto Monroyo y Mahaguay was found guilty beyond reasonable doubt by the Court of Appeals (CA) of three (3) counts of Acts of Lasciviousness and one (1) count of Qualified Rape. The CA decision was affirmed with modifications by the Supreme Court in a Resolution dated June 28, 2017. Procedural History: The Supreme Court affirmed the CA's decision finding the accused-appellant guilty of the said offenses and imposing penalties, including imprisonment and monetary awards for civil indemnity, moral damages, and exemplary damages. The Petition: The accused-appellant timely moved for reconsideration of the Supreme Court's decision. However, the Bureau of Corrections informed the Court that the accused-appellant had died on August 15, 2018, prior to the final resolution of his appeal.
Issue(s)
Whether the death of the accused-appellant prior to final conviction extinguishes his criminal and civil liabilities. Whether the Supreme Court's Decision dated June 28, 2017, should be set aside and a new one entered dismissing the criminal cases.
Ruling
The Supreme Court resolved to set aside its Decision dated June 28, 2017, and to dismiss the criminal cases against accused-appellant Norieto Monroyo y Mahaguay by reason of his death. The case was declared closed and terminated.
Ratio Decidendi
On the issue of the death of the accused-appellant prior to final conviction: The Court reiterated the prevailing law and jurisprudence that the death of an accused prior to final conviction extinguishes criminal liability. Article 89(1) of the Revised Penal Code explicitly states that criminal liability is totally extinguished by the death of the convict as to personal penalties. Furthermore, pecuniary penalties are extinguished only when the death of the offender occurs before final judgment. This principle was thoroughly explained in People v. Culas, where it was clarified that the death of the accused pending appeal extinguishes both criminal liability and civil liability based solely on the offense committed (civil liability ex delicto). The Court clarified that while civil liability ex delicto is extinguished, civil liability that may be predicated on sources of obligation other than the offense itself, such as law, contracts, quasi-contracts, or quasi-delicts, may survive. In such cases, a separate civil action may be filed against the estate of the accused. This is in accordance with Article 1157 of the Civil Code, which enumerates the other sources of obligations. The offended parties need not fear prescription, as the statute of limitations is deemed interrupted during the pendency of the criminal case. On the dismissal of the criminal cases: Given that the accused-appellant died prior to the final judgment by the Supreme Court, the criminal action is rendered dismissible as there is no longer a defendant to stand trial. Consequently, the civil action instituted for the recovery of civil liability ex delicto is also ipso facto extinguished, as it is grounded on the criminal action. Therefore, the Court found it necessary to set aside its previous decision and dismiss the criminal cases.
Main Doctrine
The death of an accused prior to final conviction extinguishes both criminal liability and civil liability ex delicto. However, civil liability arising from other sources of obligation may survive and be pursued through a separate civil action.