People v. Robles
REITERATIONFacts
The Antecedents: The case involves accused-appellants Edgar Robles and Wilfredo Robles, who were charged with Murder. The Court of Appeals (CA) rendered a Decision dated November 29, 2016, finding them guilty beyond reasonable doubt of Murder and sentencing them to suffer the penalty of reclusion perpetua, with solidary payment of civil indemnity, moral damages, exemplary damages, and temperate damages to the heirs of the victim, Dan Elvie Sioco. Procedural History: The Supreme Court, in a Resolution dated November 19, 2018, adopted the CA's Decision. However, before an Entry of Judgment could be issued, the Court received a Notice of Death dated January 4, 2019, informing the Court of Edgar Robles' death on December 15, 2018, evidenced by a Certificate of Death. The Petition: The accused-appellants appealed their conviction for Murder.
Issue(s)
Whether the criminal case against Edgar Robles should be dismissed due to his death prior to final conviction. Whether the civil liability of Edgar Robles is extinguished by his death, and if so, to what extent.
Ruling
The Court resolved to modify its Resolution dated November 19, 2018, by dismissing the criminal case against accused-appellant Edgar Robles by reason of his supervening death prior to his final conviction, and declared the case closed and terminated as to him. The civil action instituted for the recovery of civil liability ex delicto as to Edgar Robles is also extinguished.
Ratio Decidendi
On the dismissal of the criminal case against Edgar Robles due to his death: Article 89(1) of the Revised Penal Code explicitly states that criminal liability is totally extinguished by the death of the accused. This principle is well-established in jurisprudence. Edgar Robles died on December 15, 2018, prior to the final conviction by the Supreme Court. Therefore, his criminal liability is extinguished. The Court's Resolution dated November 19, 2018, which affirmed the CA decision, was not yet final as an Entry of Judgment had not been issued. Thus, the supervening death of Edgar Robles necessitates the dismissal of the criminal case against him. On the extinguishment of civil liability ex delicto and the survival of other civil liabilities: In line with the extinguishment of criminal liability, the civil action instituted for the recovery of civil liability ex delicto is also ipso facto extinguished upon the death of the accused before final judgment. This is because the civil liability ex delicto is directly based on and arises solely from the criminal offense committed. As clarified in People v. Culas, the death of the accused prior to final judgment terminates not only his criminal liability but also the civil liability ex delicto. Therefore, the claims for civil indemnity, moral damages, exemplary damages, and temperate damages against Edgar Robles, insofar as they are based solely on the crime of Murder, are extinguished. While civil liability ex delicto is extinguished, the Court clarified that Edgar Robles' civil liability in connection with his acts against the victim may still be based on other sources of obligation enumerated in Article 1157 of the Civil Code, such as law, contracts, quasi-contracts, or quasi-delicts. If such other sources exist, the victim's heirs may file a separate civil action against Edgar Robles' estate to pursue these claims. This separate action would be pursued independently of the criminal case and subject to the rules governing civil procedure. The heirs are not precluded from filing such an action by prescription, as the statute of limitations is deemed interrupted during the pendency of the criminal case, pursuant to Article 1155 of the Civil Code.
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 in a separate civil action against the estate of the deceased.