People v. Corrobella
REITERATIONFacts
The Antecedents: The Court of Appeals (CA) rendered a Decision dated November 29, 2016, finding accused-appellant Antonio "Pay Tonyo" Corrobella guilty beyond reasonable doubt of three (3) counts of Statutory Rape. The CA sentenced him to suffer the penalty of reclusion perpetua and to pay damages. Procedural History: In a Resolution dated January 8, 2018, the Supreme Court affirmed the CA Decision in toto. Accused-appellant filed a Motion for Reconsideration (MR) on February 22, 2018. While the MR was pending, the Court received a notification from the Bureau of Corrections regarding the death of the accused-appellant on January 14, 2020. The Petition: The accused-appellant filed a motion for reconsideration of the Supreme Court's Resolution affirming his conviction.
Issue(s)
Whether the criminal case against the accused-appellant should be dismissed due to his death pending appeal. Whether the civil liability ex delicto is extinguished by the death of the accused-appellant prior to final conviction. Whether a separate civil action can be pursued for civil liabilities arising from sources other than the offense committed, and the procedure for pursuing such liabilities.
Ruling
The Court resolved to set aside its Resolution dated January 8, 2018, dismiss the criminal case by reason of the death of accused-appellant Antonio "Pay Tonyo" Corrobella, and declare the case closed and terminated. No costs. Let entry of judgment be issued immediately.
Ratio Decidendi
On the dismissal of the criminal case due to death: Under Article 89 (1) of the Revised Penal Code, criminal liability is totally extinguished by the death of the accused. Since the accused-appellant died while his appeal was pending before the Supreme Court, and prior to final conviction, his criminal liability is extinguished. The criminal action itself is rendered dismissible as there is no longer a defendant to stand as the accused. On the extinguishment of civil liability ex delicto: The death of the accused prior to final judgment also extinguishes the civil liability that is directly arising from and based solely on the offense committed, also known as civil liability ex delicto. This is because the civil action for the recovery of such liability is deemed ipso facto extinguished, being grounded on the criminal action. On the survival of other civil liabilities and the procedure for pursuing them: Notwithstanding the extinguishment of civil liability ex delicto, the claim for civil liability may survive if it can be predicated on a source of obligation other than the offense committed, as enumerated in Article 1157 of the Civil Code. These other sources include law, contracts, quasi-contracts, and quasi-delicts. In such cases, a separate civil action may be filed against the estate of the accused-appellant. If the civil liability survives based on other sources of obligation, the private offended party may pursue this claim by filing a separate civil action. This action can be enforced against the executor or administrator of the accused-appellant's estate, depending on the source of the obligation. The statute of limitations for such a civil liability is deemed interrupted during the pendency of the criminal case, as per Article 1155 of the Civil Code.
Main Doctrine
The death of an accused prior to final conviction by the Supreme Court 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.