G.R. No. 229722 - People vs. De Chavez, Jr. y Escobido

On February 14, 2000, at approximately 5:15 p.m., in Barangay Lipahan, San Juan, Batangas, the accused-appellant Dionisio de Chavez, Jr. y Escobido, armed with a balisong knife, along with his co-accused Manolito de Chavez, allegedly conspired and acted in common accord.
The accused purportedly attacked Virgilio A. Matundan suddenly and without warning, inflicting stab wounds on his back that directly caused his death, in an act characterized by treachery, evident premeditation, and the absence of any justifiable cause.

Co-accused Manolito de Chavez was arrested while accused-appellant de Chavez initially evaded arrest.
Pre-trial proceedings ensued; however, before trial could commence, co-accused Manolito died.
On February 26, 2004, the RTC dismissed the case against Manolito and archived the case against de Chavez, who was still at large.
Accused-appellant de Chavez was eventually arrested on March 17, 2005, leading to the revival of his case.

After trial on the merits, the Regional Trial Court (RTC) of Rosario, Batangas, Branch 87, rendered a Decision on November 22, 2012.

The RTC found accused-appellant de Chavez guilty beyond reasonable doubt of murder under Article 248 of the Revised Penal Code, as amended by Republic Act No. 7659.
The RTC imposed the penalty of reclusion perpetua, along with various accessory penalties.
Additionally, the RTC ordered the payment of civil indemnity, moral damages, exemplary damages, and temperate damages to the heirs of the deceased amounting to Php75,000.00 each for the first three categories and Php25,000.00 for temperate damages.

The Court of Appeals affirmed the RTC Decision on June 29, 2016, thereby sustaining the finding of guilt and the imposed penalties.
Accused-appellant de Chavez then filed the present appeal challenging the decision.

During the pendency of the appeal, on August 10, 2017, Police Superintendent I Roberto R. Rabo of the New Bilibid Prison informed the Court in a letter that de Chavez had died on December 9, 2016, at the New Bilibid Prison Hospital.
A certified true copy of the Certificate of Death was submitted, confirming the death.
Consequently, pursuant to Paragraph 1, Article 89 of the Revised Penal Code, the criminal case, including the appeal, was dismissed as the death of the accused extinguished his criminal liability and related pecuniary penalties, provided the death occurred before final judgment.
The Court further explained that the heirs of the victim may still pursue a separate civil action against the estate of de Chavez if the claim is based on other sources of obligation aside from the delict.

Whether the death of the accused-appellant during the pendency of his appeal automatically extinguishes his criminal liability and the associated pecuniary penalties arising from the offense.

This includes examining the application of Paragraph 1, Article 89 of the Revised Penal Code regarding the effect of death on criminal and civil liabilities.

Whether the prior decisions of the RTC and the Court of Appeals should stand notwithstanding the subsequent death of the accused-appellant.

Consideration is given to whether the appellate decision remains operative in view of the extinguishment of the accused’s liabilities by his death.

Whether the heirs of the deceased victim may still have a valid claim for civil damages under principles distinguishing civil liability ex delicto from other sources of obligation.

Assessment of the viability of filing a separate civil action against the estate of the deceased accused based on alternative sources of obligation.