People v. Maylon
REITERATIONFacts
The Antecedents: Accused-appellants Jonathan Maylon y Alvero alias "Jun Puke" and Arnel Estrada y Glorian were found guilty beyond reasonable doubt of violating Section 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). Maylon was also found guilty of violating Section 5 of the same Act. Procedural History: The Court of Appeals (CA) affirmed the trial court's decision. Subsequently, the Supreme Court, in a Decision dated March 11, 2019, affirmed the CA's ruling. The Petition: Aggrieved, the accused-appellants filed a Motion for Reconsideration. During the pendency of this motion, the Court received information that Arnel Estrada y Glorian had died on April 26, 2018, prior to the final conviction by the Supreme Court.
Issue(s)
Whether the supervening death of accused-appellant Arnel Estrada y Glorian pending appeal extinguishes his criminal liability. Whether the issues raised in the Motion for Reconsideration of accused-appellant Jonathan Maylon y Alvero warrant a reversal of the Court's Decision.
Ruling
The Court resolved to deny the Motion for Reconsideration of Jonathan Maylon y Alvero and to modify its Decision dated March 11, 2019, by dismissing Criminal Case No. 2014-4407-D-MK against Arnel Estrada y Glorian due to his supervening death, declaring the case closed and terminated.
Ratio Decidendi
On the supervening death of Arnel Estrada y Glorian: The Court held that the death of an accused pending appeal of their conviction extinguishes their criminal liability. Citing Article 89(1) of the Revised Penal Code, the Court explained that criminal liability is totally extinguished by the death of the convict as to personal penalties, and pecuniary penalties are extinguished if death occurs before final judgment. This principle was further elaborated in People v. Monroyo, which clarified that death pending appeal extinguishes both criminal and civil liability based solely on the offense committed. The Court emphasized that if civil liability survives, it must be predicated on a source of obligation other than delict, such as law, contracts, quasi-contracts, or quasi-delicts, and pursued through a separate civil action. In this case, Estrada's death prior to final judgment rendered the criminal action against him dismissible as there was no longer a defendant to stand as the accused. The Court thus modified its previous decision to dismiss the case against Estrada. On the Motion for Reconsideration of Jonathan Maylon y Alvero: The Court found that the issues raised by Maylon in his Motion for Reconsideration were merely a rehash of the grounds already evaluated and passed upon in the assailed Decision. Consequently, the Court found no cogent reason to reverse its previous ruling, thereby denying his motion.
Main Doctrine
The death of an accused pending appeal of their conviction extinguishes both criminal and civil liability arising solely from the offense, leading to the dismissal of the criminal case.