G.R. No. 250980 - People vs. Caloring

Rogelio Caloring (accused-appellant), together with Crispin Araneta y Pelaez, Lynfer Bicodo y Baylon, Annabelle Olidan y Araneta, Benjamin Olidan y Erlandez, Godofredo Navanes y Lorizo, Rey Alada, Police Officer I Jose Lonmar Zapatos y Fiel, and PO1 Antonio Castillo y Domingo, were charged with Kidnapping for Ransom under Article 267 of the Revised Penal Code (RPC).
The kidnapping involved four victims: Vinz Sermonia y de la Cruz (11 years old), Klevwelt Sermonia y dela Cruz (11 years old), Genritz Sermonia y de la Cruz (9 years old), and Eulalia Cuevas y Madara.
The offense allegedly occurred on or about August 30, 2005, in Filinvest II, Quezon City.
The accused were charged in one (1) Information that effectively encompassed kidnapping of all four victims collectively.

At arraignment, all accused entered pleas of "not guilty" except Rey Alada, who was not arraigned as records show no entry of plea or arraignment for him.
The defense admitted the identification of accused, jurisdiction of the court, and the minors' ages during pre-trial.
Trial on the merits proceeded, after which both prosecution and defense rested.

Branch 225, RTC Quezon City, found all accused except Navanes guilty beyond reasonable doubt. Navanes’ liability was extinguished due to death after arraignment but prior to judgment promulgation.
Each accused was sentenced to suffer reclusion perpetua.
The RTC ordered full indemnification: P30,000 moral damages and P30,000 exemplary damages for each victim, with legal interest.

Appeals of Araneta, Annabelle, and Bicodo were dismissed or withdrawn, leaving only accused-appellant, Benjamin, and PO1 Zapatos’ appeals for resolution.
The CA, in its Decision dated June 7, 2019, affirmed the conviction but modified the damages awarded.
The CA increased moral damages, exemplary damages, and awarded civil indemnity of P100,000 each for each victim, with 6% interest per annum.

The Bureau of Corrections and New Bilibid Prison officially informed the Court that Rogelio Caloring died on March 10, 2021.
The Supreme Court considered the death of accused-appellant during appeal, resulting in extinguishment of criminal and civil liability.
The Court discussed procedural defects related to the Information being duplicitous for charging multiple counts in one Information but noted all accused had waived the defect by not raising a motion to quash before pleading.
Rey Alada’s conviction was found void because he was never arraigned, and due process requires arraignment before trial and conviction.

Whether the death of accused-appellant during the pendency of his appeal extinguishes his criminal and civil liability.
Whether the Information charging four victims in one count of Kidnapping for Ransom is defective and, if so, whether the accused waived the defect.
Whether Rey Alada’s conviction is valid despite no arraignment having been conducted.