GR L 30256; (July, 1984) (Digest)
G.R. No. L-30256 July 16, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. AURELIO ONAROSA, defendant-appellant.
FACTS
The defendant-appellant, Aurelio Onarosa, was convicted by the Court of First Instance of Samar for a crime resulting in the death of Juan Balagasay. The case was elevated to the Supreme Court on appeal. However, during the pendency of the appeal, the accused-appellant died on January 26, 1984. Subsequently, the Supreme Court rendered a decision on February 29, 1984, affirming the factual findings and the guilt of the accused-appellant as established by the trial court.
The victim’s heirs did not reserve their right to institute a separate civil action for damages. Following the appellant’s death, the primary issue became the legal effect of his demise on both his criminal liability and the corresponding civil liability arising from the crime.
ISSUE
Whether the Supreme Court can proceed to rule on the civil liability of the deceased accused-appellant despite the extinction of his criminal liability due to his death.
RULING
Yes. The Supreme Court ruled that while the death of the accused pending appeal extinguishes his criminal liability, it does not necessarily extinguish the civil liability arising from the crime. The Court, citing People vs. Sendaydiego, resolved to exercise jurisdiction over the accused’s civil liability. The legal logic is that the civil liability survives because it is a distinct obligation to repair the wrong done to the private offended party.
The Court found it duly established beyond reasonable doubt that the deceased appellant was responsible for the victim’s death. Since the heirs of the victim did not reserve the right to file an independent civil action, requiring them to initiate a separate suit for indemnity would be a superfluity and an undue burden. It would be an absurdity, as noted in the concurring opinion, to compel a new civil suit to prove by mere preponderance of evidence what has already been proven beyond reasonable doubt in the criminal case.
Therefore, in the interest of justice and fairness, the Court imposed the civil liability upon the estate of the deceased Aurelio Onarosa, ordering it to indemnify the heirs of Juan Balagasay in the amount of Thirty Thousand Pesos (P30,000.00).