GR 229722; (December, 2017) (Digest)
G.R. No. 229722 , December 13, 2017
People of the Philippines, Plaintiff-Appellee vs. Dionisio De Chavez, Jr. y Escobido, Accused-Appellant
FACTS
Accused-appellant Dionisio de Chavez, Jr. was charged with Murder for the stabbing death of Virgilio Matundan on February 14, 2000. The Regional Trial Court found him guilty beyond reasonable doubt and sentenced him to reclusion perpetua, ordering him to pay various damages to the victim’s heirs. The Court of Appeals affirmed this decision in full.
During the pendency of his appeal before the Supreme Court, the Court received official communication from the New Bilibid Prison informing it that the accused-appellant had died on December 9, 2016, at the prison hospital. A certified copy of his death certificate was attached to the report.
ISSUE
Whether the death of the accused-appellant during the pendency of his appeal extinguishes his criminal and civil liabilities.
RULING
Yes. The Supreme Court set aside the appealed decision and dismissed the criminal case. The legal logic is grounded in Article 89 of the Revised Penal Code, which provides that the death of the convict extinguishes personal criminal penalties. Applying the controlling precedent in People v. Bayotas, the Court held that the death of an accused pending appeal extinguishes both his criminal liability and the civil liability that is based solely on the crime (ex delicto).
Since the judgment against De Chavez was not yet final at the time of his death, his criminal liability is totally extinguished. Consequently, the civil liabilities for indemnity, moral, exemplary, and temperate damages imposed by the lower courts, being civil liabilities arising exclusively from the crime, are also extinguished. However, the Court clarified that a separate civil action against the estate of the accused may proceed if the claim can be predicated on other sources of obligation under the Civil Code, such as law, contracts, quasi-contracts, or quasi-delicts, subject to the applicable rules of procedure. The heirs of the victim are not precluded from pursuing such an independent civil action.