G.R. No. 214875 . October 17, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ARIEL LAYAG, Accused-Appellant.

FACTS

The Supreme Court, in a Resolution dated August 3, 2015, affirmed with modification the Court of Appeals Decision finding accused-appellant Ariel Layag guilty beyond reasonable doubt of one count of Qualified Rape by Sexual Intercourse, two counts of Qualified Rape by Sexual Assault, and one count of Acts of Lasciviousness. The Court imposed corresponding penalties and awarded damages. An Entry of Judgment was issued on October 14, 2015, declaring the Resolution final and executory.
Subsequently, the Court received a letter from the Bureau of Corrections dated July 18, 2016, informing it of Layag’s death on July 30, 2015. This death occurred prior to the promulgation of the Court’s August 3, 2015 Resolution. Despite the finality of the judgment, the Court opted to reopen the case in light of this supervening event.

ISSUE

Whether the death of the accused-appellant pending appeal, but before the Court’s final judgment of conviction, warrants the dismissal of the criminal cases against him.

RULING

Yes. The Court set aside its prior Resolution and dismissed all criminal cases against Layag by reason of his death. The legal logic proceeds from two key principles. First, the Court has the inherent power to relax the doctrine of immutability of final judgment under compelling circumstances. The death of the accused, which the Court was belatedly informed of after it had rendered a decision, constitutes such a special and compelling circumstance warranting a re-examination of the case to serve substantial justice.
Second, and decisively, 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 prevailing jurisprudence, notably People v. Bayotas and People v. Egagamao, the death of an accused pending appeal extinguishes his criminal liability and the civil liability arising exclusively from the crime (civil liability ex delicto). Since Layag died before the Court’s judgment of conviction became final, the criminal actions against him must be dismissed. Consequently, the civil liability for damages awarded in the criminal case, being based solely on the delict, is ipso facto extinguished.
However, the Court clarified that this extinction applies only to civil liability ex delicto. The private offended party may pursue a separate civil action against the estate of the accused if the claim can be anchored on other sources of obligation under the Civil Code, such as quasi-delict, contract, or law. The dismissal is thus without prejudice to the filing of such an independent civil action.