G.R. No. 225607. March 28, 2022.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PAUL ANDERSON y JEFFREY, accused-appellant.

FACTS

The Court initially affirmed the Decision of the Court of Appeals finding accused-appellant Paul Anderson y Jeffrey guilty beyond reasonable doubt of two counts of Rape by Sexual Assault and Acts of Lasciviousness. However, after the issuance of the Court’s Resolution affirming the conviction, Anderson’s counsel filed a Manifestation and Undertaking with Motion to Dismiss, informing the Court that Anderson had already died on April 21, 2007, as evidenced by a Certificate of Death. This death occurred during the pendency of the criminal case, which was only resolved by the Court in its Resolution dated April 26, 2017.

ISSUE

Whether the supervening death of the accused-appellant during the pendency of his appeal extinguishes his criminal and civil liabilities.

RULING

Yes. Under Article 89(1) of the Revised Penal Code, criminal liability is totally extinguished by the death of the convict, as to personal penalties, and as to pecuniary penalties, liability is extinguished when death occurs before final judgment. The civil liability arising from the crime (ex delicto) is also ipso facto extinguished as it is grounded on the criminal action. The rationale is that upon an accused-appellant’s death pending appeal, there is no longer a defendant to stand as the accused.
Applying this, the Court held that had it been timely informed of Anderson’s death, his conviction would not have been affirmed, as his criminal liability and civil liability ex delicto had already been extinguished. Consequently, the Court set aside its earlier Resolution affirming the conviction and dismissed the criminal cases by reason of Anderson’s supervening death prior to his final conviction.
The Court clarified, citing People v. Culas, that while civil liability ex delicto is extinguished, the civil liability arising from other sources of obligation (such as law, contracts, quasi-contracts, or quasi-delicts) survives. A separate civil action for such liability may be pursued against the executor/administrator or the estate of the accused.