The Supreme Court held that the death of an accused-appellant, Edgar Robles, prior to a final conviction, results in the dismissal of the criminal case against him. This means that the criminal liability, along with the civil liability arising solely from the crime, is extinguished. However, the heirs of the victim retain the right to pursue a separate civil action against the estate of the deceased based on other sources of obligation, such as contracts or quasi-delicts. This ruling underscores the principle that final judgment is a prerequisite for the full enforcement of criminal and associated civil liabilities.

Justice Served, Even in Death: Examining the Extinguishment of Criminal Liability

The case of People v. Edgar Robles centers on the tragic consequences following a murder, compounded by the death of one of the accused during the appellate process. Edgar Robles, along with others, was found guilty of murder by the Court of Appeals. However, before the Supreme Court could issue a final judgment, Edgar passed away. This prompted the Supreme Court to revisit its earlier resolution affirming the conviction, leading to a crucial examination of the effects of death on criminal and civil liabilities. The legal question at the heart of this case is: what happens to the criminal and civil liabilities of an accused when they die before a final judgment is rendered?

The Supreme Court anchored its decision on Article 89(1) of the Revised Penal Code, which explicitly states that criminal liability is totally extinguished by the death of the convict, especially concerning personal penalties. Regarding pecuniary penalties, liability is extinguished only if the offender dies before final judgment. The Court quoted:

Article 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 pecuniary penalties, liability therefor is extinguished only when the death of the offender occurs before final judgment;

Building on this foundation, the Court referenced People v. Culas to comprehensively explain the ramifications of an accused’s death pending appeal. The Court emphasized that:

1. Death of the accused pending appeal of his conviction extinguishes his criminal liability[,] as well as the civil liability[,] based solely thereon…

2. Corollarily, the claim for civil liability survives notwithstanding the death of accused, if the same may also be predicated on a source of obligation other than delict. Article 1157 of the Civil Code enumerates these other sources of obligation from which the civil liability may arise as a result of the same act or omission:

a) Law
b) Contracts
c) Quasi-contracts
d) x x x
e) Quasi-delicts

3. Where the civil liability survives, as explained in Number 2 above, an action for recovery therefor may be pursued but only by way of filing a separate civil action and subject to Section 1, Rule 111 of the 1985 Rules on Criminal Procedure [,] as amended. This separate civil action may be enforced either against the executor/administrator or the estate of the accused, depending on the source of obligation upon which the same is based as explained above.

4. Finally, the private offended party need not fear a forfeiture of his right to file this separate civil action by prescription, in cases where during the prosecution of the criminal action and prior to its extinction, the private offended party instituted together therewith the civil action. In such case, the statute of limitations on the civil liability is deemed interrupted during the pendency of the criminal case, conformably with [the] provisions of Article 1155 of the Civil Code, that should thereby avoid any apprehension on a possible privation of right by prescription.

The Supreme Court clarified that while the criminal action against Edgar was extinguished upon his death, the civil liability stemming from his actions might still be pursued through a separate civil action against his estate. This distinction is crucial, as it highlights the different sources of obligations under the law. Civil liability can arise not only from criminal acts (ex delicto) but also from other sources like contracts, quasi-contracts, or quasi-delicts, as stipulated in Article 1157 of the Civil Code. This ensures that the victim’s heirs are not entirely deprived of recourse, especially if the wrongful act also constitutes a breach of contract or a quasi-delict.

Furthermore, the ruling underscores the importance of final judgment in criminal cases. The death of the accused before a final verdict effectively nullifies the conviction and its direct consequences, including imprisonment and fines. However, it does not necessarily absolve the deceased of all liabilities, particularly if these liabilities can be established independently of the criminal act. This principle balances the rights of the accused with the rights of the victims, ensuring that justice is pursued within the bounds of the law.

The implication of this ruling extends to all criminal cases where the accused dies during the appellate process. It reinforces the principle that the presumption of innocence remains until a final conviction is secured. The ruling also provides clarity on the recourse available to victims and their families when the accused dies before final judgment. They are not left without options but can pursue civil remedies to seek compensation for damages suffered.

FAQs

What happens to a criminal case if the accused dies before final judgment?	The criminal liability is extinguished, leading to the dismissal of the case against the accused.
What happens to the civil liability in such cases?	Civil liability directly arising from the crime is also extinguished. However, civil liability based on other sources, like contracts or quasi-delicts, may survive and be pursued through a separate civil action.
What is the basis for extinguishing criminal liability upon death?	Article 89(1) of the Revised Penal Code stipulates that criminal liability is totally extinguished by the death of the convict, especially concerning personal penalties.
Can the victim’s family still seek compensation if the accused dies?	Yes, they can file a separate civil action against the estate of the deceased based on sources of obligation other than the criminal act itself.
What are the other sources of obligation that can be the basis of a civil action?	Article 1157 of the Civil Code enumerates law, contracts, quasi-contracts, delicts, and quasi-delicts as sources of obligation.
Does the statute of limitations affect the filing of a separate civil action?	No, the statute of limitations is deemed interrupted during the pendency of the criminal case if the civil action was instituted together with the criminal action.
What is the significance of a ‘final judgment’ in this context?	A final judgment is a prerequisite for the full enforcement of criminal and associated civil liabilities. Death before final judgment alters the legal landscape significantly.
Where can one find the rules regarding the pursuit of civil liability after the accused’s death?	Section 1, Rule 111 of the 1985 Rules on Criminal Procedure, as amended, provides the rules for pursuing a separate civil action.

In conclusion, the Supreme Court’s resolution in People v. Edgar Robles underscores the fundamental principles governing criminal and civil liabilities in the context of an accused’s death before final judgment. It clarifies the extent to which liabilities are extinguished and the alternative remedies available to victims, ensuring a balance between justice and the rights of all parties involved.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Edgar Robles, G.R. No. 229943, July 10, 2019