GR 121940; (December, 2001) (Digest)
March 17, 2026GR 153799; (September, 2012) (Digest)
March 17, 2026G.R. No. 211166, June 5, 2017
People of the Philippines, Plaintiff-Appellee vs. Porferio Culas y Raga, Accused-Appellant
FACTS
The Court, in a Resolution dated July 18, 2014, adopted the Court of Appeals Decision dated July 25, 2013, which found accused-appellant Porferio Culas y Raga guilty beyond reasonable doubt of Statutory Rape. The Court affirmed the penalty of reclusion perpetua without parole and modified the amounts for civil indemnity and damages. However, before an Entry of Judgment could be issued, the Bureau of Corrections informed the Court via a letter dated September 16, 2014, that the accused-appellant had already died on February 8, 2014, as evidenced by an attached Certificate of Death.
ISSUE
Whether the death of the accused-appellant pending the finality of the judgment of conviction extinguishes his criminal and civil liabilities.
RULING
Yes. The death of the accused-appellant prior to the finality of the judgment of conviction renders the criminal case against him dismissible. Article 89(1) of the Revised Penal Code provides that criminal liability is totally extinguished by the death of the convict, with pecuniary penalties also extinguished if death occurs before final judgment. Applying the jurisprudence in People v. Layag, the Court held that the death of an accused pending appeal extinguishes both his criminal liability and the civil liability arising exclusively from the crime (ex delicto). Consequently, the criminal action is extinguished as there is no longer a defendant, and the civil action for recovery of civil liability ex delicto instituted with it is ipso facto extinguished.
However, the Court clarified that the extinction of civil liability ex delicto does not preclude the recovery of civil liability that may be predicated on other sources of obligation under Article 1157 of the Civil Code, such as law, contracts, quasi-contracts, or quasi-delicts. For such claims, the private offended party may pursue a separate civil action against the executor, administrator, or the estate of the deceased accused, subject to applicable procedural rules. Accordingly, the Court set aside its July 18, 2014 Resolution and dismissed the criminal case by reason of the accused-appellant’s death.
