G.R. No. 120881 - People vs. Germina y Maldo

The accused-appellant, Porferio Culas y Raga, was charged and subsequently found guilty beyond reasonable doubt of the crime of Statutory Rape under paragraph 1 (d), Article 266-A in relation to Article 266-B (1) of the Revised Penal Code.
The Court of Appeals (CA) rendered a decision on July 25, 2013, which was adopted by the Supreme Court in its Resolution dated July 18, 2014.
In the CA decision, the accused was sentenced to reclusion perpetua without eligibility for parole, and was further ordered to pay P100,000.00 for civil indemnity, P100,000.00 for moral damages, and P100,000.00 for exemplary damages, with legal interest accruing at 6% per annum.

Before an Entry of Judgment could be issued based on the adopted decision, the Court received a Letter from the Bureau of Corrections, dated September 16, 2014, indicating that the accused-appellant had died on February 8, 2014.
This communication was supported by the submission of a Certificate of Death, signaling the need to reconsider the criminal proceedings in light of the death of the accused.

Under Article 89(1) of the Revised Penal Code, criminal liability is totally extinguished by the death of the accused, provided that the death occurs before final judgment.
Jurisprudence, particularly in People v. Layag, has clarified that if an accused dies while an appeal is pending, both the criminal and related civil liabilities (arising solely from the delict) are terminated.

Although the criminal case becomes dismissible due to the absence of a defendant, the possibility remains for civil liability to survive if such liability may be based on other sources of obligation (e.g., contracts, quasi-contracts, or quasi-delicts) beyond the delict.
In instances where a separate civil action is pursued concurrently with the criminal case, the statute of limitations for the civil claim is effectively interrupted, thereby protecting the private offended party’s right to recovery.

Whether the death of the accused-appellant prior to the entry of final judgment automatically renders the criminal case dismissible.

The core question centers on the application of Article 89(1) of the Revised Penal Code in the context where the accused dies during the pendency of appeal.
The issue also examines the impact of the death on the court’s ability to proceed with an entry of judgment based on the previous conviction.

Whether the related civil liability, as awarded in the criminal proceeding, survives the death of the accused-appellant.

The analysis concerns if civil liability arising specifically from the delict is extinguished by the accused’s death, effectively terminating the civil action initiated within the criminal case.
It also explores the possibility of a separate civil action if the liability is founded on obligations other than the delict.

The proper procedure for dismissing the criminal case and the subsequent handling of any civil actions that may stem from the offense committed.