Case Digest (G.R. No. 175784)
Case Digest (G.R. No. 175784)
Facts:
People of the Philippines v. Jaime Ayochok y Tauli, G.R. No. 175784, August 25, 2010, First Division, Leonardo‑De Castro, J., writing for the Court.In an Amended Information dated September 21, 2001, Prosecutor Benedicto T. Carantes charged Jaime Ayochok y Tauli (accused‑appellant) with Murder, alleging that on or about July 15, 2001 in Baguio City the accused, armed with a gun and with intent to kill, shot SPO1 Claudio Caligtan by means of treachery and cruelty while the victim was relieving himself and unable to defend himself. Ayochok pleaded not guilty at arraignment.
After trial, the Regional Trial Court (RTC), Branch 6, Baguio City, rendered its Decision on August 13, 2003 finding Ayochok guilty beyond reasonable doubt of Murder (Article 248, Revised Penal Code), qualified by treachery, and sentenced him to reclusion perpetua with awards of civil indemnity, moral and actual damages, unearned income, and costs. Ayochok was committed to New Bilibid Prison on October 31, 2003.
The case was initially elevated to the Supreme Court for automatic review and docketed as G.R. No. 161469, but pursuant to People v. Mateo (G.R. Nos. 147678‑87, July 7, 2004) the record was transferred to the Court of Appeals, where it was docketed as CA‑G.R. CR No. 00949. The Court of Appeals issued its Decision on June 28, 2005, affirming the RTC's conviction but reducing the amounts of the civil awards. Ayochok moved for reconsideration, then sought to withdraw that motion and appeal to the Supreme Court; the Court of Appeals denied both his motion to withdraw and his reconsideration. The records were elevated to the Supreme Court and docketed as G.R. No. 175784 after the Judicial Records Division transmitted them on December 29, 2006.
The parties filed supplemental pleadings as directed and the case was submitted for resolution on August 6, 2007. While the appeal was pending, the Bureau of Corrections informed the Court by letter dated February 16, 2010 that Ayochok died on January 15, 2010; the New Bilibid Prison later furnished a certified copy of his death certificate (submitted June 22, 2010). The Supreme Court then considered the legal effect of the accused's death on the pending appeal and on any criminal and civil liabilities arising from the conviction, citing Article 89(1) of the Revised Penal Code, People v. Bayotas (G.R. No. 102007, September 2, 1994) and related authorities.
Issues:
- Does the death of the accused during the pendency of his appeal extinguish his criminal liability and the civil liability arising solely from the offense (civil liability ex delicto)?
- If civil liability survives because it is based on sources other than delict (e.g., law, contract, quasi‑delict), what is the appropriate mode to pursue recovery and against whom may it be enforced?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)