G.R. No. L-27952 - Testate Estate of Ramirez vs. Vda. de Ramirez

Accused-appellant Ruben Calomia was charged before the Regional Trial Court (RTC) of Loay, Bohol, Branch 50, in Criminal Case Nos. 1317 and 1318.
He was accused of committing two counts of qualified rape, specifically involving his minor daughter, identified as AAA.
The sexual offenses allegedly occurred in two separate incidents: one in August 2007 and the other in April 2008.

After a trial on the merits, on March 11, 2015, the RTC rendered its decision finding Calomia guilty beyond reasonable doubt for both counts of qualified rape.
The RTC found him guilty of (Qualified) Incestuous Rape in Criminal Case No. 1317 and Statutory Incestuous Rape in Criminal Case No. 1318.
Although the offenses were punishable by death, the imposition of the death penalty was prohibited by R.A. No. 9346; hence, reclusion perpetua was imposed.
The court also imposed penalties for the victim AAA which included civil indemnity, moral damages, and exemplary damages:

Accused-appellant Calomia filed an appeal, which was docketed with the Court of Appeals as CA-G.R. CEB-CR-HC No. 02040.
On August 26, 2016, the Court of Appeals affirmed the RTC conviction with modifications regarding the damages awarded to AAA:

The award was modified to P100,000 each for civil indemnity, moral damages, and exemplary damages.
Interest at a rate of 6% per annum was imposed on all damages from the date of finality of the decision until full payment.

Accused-appellant Calomia filed a Notice of Appeal on September 21, 2016.
The Court issued a Resolution on April 25, 2017 requiring supplemental briefs and other administrative orders relating to the transfer of the accused.
On September 4, 2017, the Court received a letter from Jail Chief Inspector Felipe A. Montejo stating that:

Calomia had died on September 29, 2015, while in the confinement of the Bohol District Jail.
His death was attributed to asphyxia due to strangulation, which was self-inflicted by hanging.
The death certificate issued by the Office of the Civil Registrar General confirmed the circumstances and location of death.

Article 89 of the Revised Penal Code stipulates that the death of an accused pending appeal extinguishes both his criminal and civil liability, with the civil liability extinguished when based solely on the offense.
Jurisprudence, particularly People v. Bayotas, reinforces that the death of the accused terminates criminal liability and, if the civil claim is solely tied to the offense, it too becomes extinguished.
In the present case, the death of Calomia occurred before the final judgment, thereby necessitating the dismissal of both the criminal prosecution and any associated civil liability based strictly on the crime.

Whether the death of accused-appellant Ruben Calomia pending his appeal extinguished his criminal liability.

The central question involves the applicability of Article 89 of the Revised Penal Code which provides that death terminates criminal and pecuniary liabilities when the death occurs before a final judgment.
The analysis included whether the accused’s death also affected civil liability directly arising from the crime.

Whether the civil indemnity, moral damages, and exemplary damages awarded to the victim AAA should survive despite the accused’s death.
The issue extends to determining if any purported civil liability may persist through alternative legal bases other than the criminal action itself.

Whether the untimely information regarding Calomia's death impacted the Court of Appeals’ prior decision.
The analysis involved understanding the relationship between the criminal case’s resolution and the subsequent legal consequences arising from the accused’s demise.