People vs. De Chavez, J.r. (2017)

PEOPLE OF THE PHILIPPINES vs. DIONISIO DE CHAVEZ, JR.

G.R. No. 229722, December 13, 2017

LEONARDO-DE CASTRO, J:

Facts: Accused-appellant de Chavez was charged with murder. On March 17, 2005, accused-appellant was arrested. After trial on the merits, the Regional Trial Court rendered a Decision finding accused-appellant guilty beyond reasonable doubt of the crime of murder.

On appeal, the Court of Appeals affirmed the Decision of the RTC. Hence, accused-appellant filed a final appeal to the Supreme Court. During the pendency appeal, accused-appellant had died on December 9, 2016 at the New Bilibid Prison Hospital.

Issue: Whether or not criminal liability of de Chavez is extinguished.

Ruling: Yes. Paragraph 1, Article 89 of the Revised Penal Code, as amended, provides the effect of death of the accused on his criminal and civil liabilities, to wit:

ART. 89. How criminal liability is totally extinguished. - Criminal liability is totally extinguished:

1. By the death of the convict, as to the personal penalties; and as to the pecuniary penalties, liability therefor is extinguished only when the death of the offender occurs before final judgment.

 It is clear that the death of accused-appellant, during the pendency of his appeal, extinguished not only his criminal liability, but also his civil liabilities arising from or based on the crime. But, as held in Bayotas, accused-appellant’s civil liability may be based on other sources of obligation other than ex delicto, in which case the heirs of the victim may file a separate civil action against the estate of accused appellant, as may be warranted by law and procedural rules.

Ratio Decidendi: The death of the accused prior to final judgment terminates his criminal liability and only the civil liability directly arising from and based solely on the offense committed.

Gist: Before the Court is an appeal filed by accused-appellant Dionisio de Chavez, Jr. assailing the Decision of the Court of Appeals, which affirmed the Decision of the Regional Trial Court of Rosario, Batangas, Branch 87.