GR 231878; (October, 2020) (Digest)
G.R. No. 231878 . October 14, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ANTONIO “PAY TONYO” CORROBELLA, ACCUSED-APPELLANT.
FACTS
The Supreme Court, in a Resolution dated January 8, 2018, affirmed the Court of Appeals’ Decision finding accused-appellant Antonio Corrobella guilty beyond reasonable doubt of three counts of Statutory Rape. He was sentenced to reclusion perpetua and ordered to pay civil indemnity, moral damages, and exemplary damages to the victim, AAA. Corrobella filed a motion for reconsideration.
Pending the resolution of this motion, the Court received official notification from the Bureau of Corrections that Antonio Corrobella had died on January 14, 2020. This event occurred before the judgment against him had attained finality, as his appeal was still pending resolution at the time of his death.
ISSUE
Whether the death of the accused-appellant pending the finality of his conviction extinguishes his criminal and civil liabilities.
RULING
Yes. The death of the accused-appellant pending appeal extinguishes both his criminal liability and the civil liability arising exclusively from the crime (civil liability ex delicto). This is grounded on Article 89(1) of the Revised Penal Code, which provides that criminal liability is totally extinguished by the death of the convict, and as to pecuniary penalties, liability is extinguished if death occurs before final judgment. Applying the doctrine established in People v. Layag, the Court held that since Corrobella died before his conviction became final, the criminal actions against him must be dismissed. Consequently, the civil liability for damages awarded in the criminal case, which is based solely on the delict, is also 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 the Civil Code, such as quasi-delict. The private offended party may pursue such claims by filing a separate civil action against the executor or administrator of the accused’s estate, subject to the applicable rules of procedure. Accordingly, the Supreme Court set aside its prior affirmance, dismissed the criminal cases, and declared the case closed and terminated.