TL;DR

In this Supreme Court Resolution, the court reiterated the principle that the death of an accused person prior to the final judgment of conviction extinguishes their criminal liability and the civil liability directly arising from the crime. The Court modified its earlier resolution to dismiss the case against Edgar Robles, who died after the Court of Appeals’ guilty verdict but before the Supreme Court’s final judgment became executory. While criminal liability is extinguished, the victim’s heirs may still pursue a separate civil action against the deceased’s estate based on other sources of obligation like quasi-delict.

Life’s End, Case Closed? The Impact of Death on Criminal Accountability

The case of People of the Philippines v. Edgar Robles presents a straightforward yet crucial question in Philippine criminal law: what happens when an accused person dies after being found guilty by a lower court but before the Supreme Court can issue a final verdict? This question hinges on the fundamental principle of the extinguishment of criminal liability by death, as enshrined in Article 89 of the Revised Penal Code. The Supreme Court, in this Resolution, clarified the application of this principle, particularly concerning Edgar Robles, one of the accused initially convicted of Murder.

The narrative began with the Court adopting the Court of Appeals’ decision which found Edgar Robles and Wilfredo Robles guilty of Murder. They were sentenced to reclusion perpetua and ordered to pay civil liabilities to the victim’s heirs. However, before the judgment could become final, Edgar Robles passed away. This supervening death prompted the Supreme Court to re-evaluate the case specifically in relation to Edgar Robles’s criminal liability. The legal framework for this re-evaluation is clear. Article 89(1) of the Revised Penal Code explicitly states:

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;

This provision is unequivocal: death before final judgment extinguishes criminal liability. The Supreme Court, citing its previous ruling in People v. Culas, reiterated that this extinguishment is total, encompassing both criminal and civil liability directly derived from the crime itself – what is legally termed civil liability ex delicto. The Court emphasized that final judgment is the critical juncture. As Edgar Robles died after the CA’s decision but before the Supreme Court’s judgment became final and executory, the principle of extinguishment due to death applied. This principle is rooted in the personal nature of criminal responsibility; punishment is meant for the individual who committed the crime, and death renders the imposition of personal penalties impossible.

However, the Court also clarified a crucial nuance regarding civil liability. While civil liability ex delicto is extinguished with the criminal action, other sources of civil obligations may still exist. Drawing from Article 1157 of the Civil Code, the Court pointed out that obligations can arise from law, contracts, quasi-contracts, delicts, and quasi-delicts. Therefore, even if the criminal liability and its directly related civil liability are extinguished, the heirs of the victim are not without recourse. They retain the right to pursue a separate civil action against the estate of Edgar Robles based on these other sources of obligation, particularly quasi-delict, which addresses fault or negligence causing damage, independent of criminal liability. This distinction is vital because it ensures that while the deceased is no longer criminally accountable, their estate may still be civilly liable for the consequences of their actions.

In practical terms, this Resolution means that for Edgar Robles, the criminal case is dismissed, and he will not be subjected to the penalties imposed by the lower courts. However, his estate is not entirely free from potential liability. The victim’s heirs can file a separate civil case to seek damages. This separate civil action would need to be pursued following the Rules of Civil Procedure and against the administrator or executor of Edgar Robles’s estate. The Court’s decision underscores the interplay between criminal and civil law in the Philippines, highlighting that while death provides a definitive end to criminal prosecution, it does not necessarily absolve all forms of accountability. The pursuit of civil remedies remains a viable option for victims and their families, ensuring a measure of justice and compensation even in cases where the accused dies before final conviction.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.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. Robles, G.R. No. 229943, July 10, 2019