Facts:
Romeo Antido y Lantayan, also known as Romeo Antigo y Lantayan alias “Jon-Jon” (hereinafter, Accused-Appellant), was found guilty of raping a woman identified as AAA. The crime occurred when AAA was forcibly taken and sexually violated by the accused. Following the incident, AAA reported the crime, leading to the filing of the case by the government against the Accused-Appellant. After a trial, the Regional Trial Court (RTC) of Manila, Branch 29, convicted the Accused-Appellant of rape under paragraph 1 of Article 266-A in relation to paragraph 5 of Article 266-B of RA 8353.
Subsequently, the Accused-Appellant appealed his conviction to the Court of Appeals (CA). On December 7, 2012, the CA affirmed the RTC’s decision, upholding the conviction and sentencing the Accused-Appellant to reclusion perpetua, alongside ordering him to pay civil indemnity, moral damages, and exemplary damages to AAA. This decision was further appealed to the Supreme Court.
However, before the Supreme Court could conclude its deliberation, the Accused-Appellant passed away on December 28, 2013, as evidenced by his Certificate of Death. Despite his death, on April 7, 2014, the Supreme Court resolved to affirm the decision of the CA, thus confirming his guilt.
Issues:
1. **Does the death of the accused-appellant prior to the final judgment extinguish his criminal liability?**
2. **What are the implications of the accused-appellant’s death on his civil liabilities?**
Court’s Decision:
1. **Extinguishment of Criminal Liability:**
Article 89 of the Revised Penal Code provides that criminal liability is totally extinguished by the death of the accused. The Court, referencing the case of *People v. Culas*, highlighted that the death of the accused pending appeal extinguishes not only his criminal liability but also his civil liability directly arising from the offense, as there is no defendant to stand as the accused. Thus, due to the Accused-Appellant’s death prior to the final ruling, his criminal case must be dismissed.
2. **Implications on Civil Liabilities:**
The civil liability founded on the criminal action (ex delicto) is also extinguished upon the death of the accused. However, citing Article 1157 of the Civil Code, the Court clarified that any civil liability predicated on sources other than delict (such as law, contracts, quasi-contracts, or quasi-delicts) survives and may be pursued in a separate civil action against the estate of the deceased.
Doctrine:
1. **Extinction of Criminal Liability with Death:** Under Philippine jurisprudence, the death of an accused pending appeal extinguishes criminal liability as well as civil liability based solely on the criminal act.
2. **Survival of Civil Liabilities:** Civil liabilities predicated on sources other than delicts may survive and can be claimed through separate civil action consistent with legal procedural rules.
Class Notes:
– **Elements of Rape (Article 266-A, Revised Penal Code)**:
1. Offender had carnal knowledge of a woman.
2. Such act was committed through force, threat, or intimidation, or when the woman is deprived of reason or otherwise unconscious, or under the age of twelve.
– **Extinguishment of Criminal Liability (Article 89, Revised Penal Code)**:
Criminal liability is extinguished by the death of the convict prior to final judgment.
– **Civil Code Article 1157:**
The sources of obligation which may create civil liability are:
a. Law
b. Contracts
c. Quasi-contracts
d. Acts or omissions punished by law (delicts)
e. Quasi-delicts
– **Procedural Rules – Rule on Subsequent Civil Actions:**
Civil actions not based solely on the criminal act can continue and should be filed separately if the criminal action is extinguished.
Historical Background:
The case of People v. Romeo Antido addresses fundamental principles of Philippine criminal jurisprudence concerning the extinguishment of criminal and associated civil liabilities due to the death of the accused during the pendency of an appeal. Rooted in the overarching doctrine established by the Revised Penal Code and elucidated in case laws such as People v. Culas, this case exemplifies the legal mechanisms ensuring that both criminal and civil obligations are treated consistently upon the termination of the accused’s life before a final judgment.
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