G.R. No. 214875 - People vs. Layag

Accused-Appellant Ariel Layag was found guilty beyond reasonable doubt by the Court of Appeals (CA) of:

One (1) count of Qualified Rape by Sexual Intercourse under Article 266-A, paragraph 1, in relation to Article 266-B(1) of the Revised Penal Code (RPC);
Two (2) counts of Qualified Rape by Sexual Assault under Article 266-A, paragraph 2, in relation to Article 266-B(1) of the RPC;
One (1) count of Acts of Lasciviousness under Article 336 of the RPC.

The Court adopted the CA Decision dated January 29, 2014, in toto via a Resolution dated August 3, 2015, affirming Layag’s guilt and sentencing him accordingly, including the award of damages to the victim.

Qualified Rape by Sexual Intercourse: Reclusion perpetua without parole; civil, moral, and exemplary damages of Php 100,000.00 each;
Qualified Rape by Sexual Assault (two counts): Imprisonment ranging from eight years and one day to seventeen years; Php 30,000.00 each for civil, moral, and exemplary damages per count;
Acts of Lasciviousness: Imprisonment from six months of arresto mayor to four years and two months of prision correccional; damages of Php 20,000.00 civil indemnity, Php 30,000.00 moral damages, Php 30,000.00 exemplary damages.
All monetary awards to earn legal interest of six percent (6%) per annum from the date of finality until full payment.

Entry of Judgment was issued on October 14, 2015, declaring finality of said Resolution.
The Court later received a letter dated July 18, 2016, from the Bureau of Corrections informing them of Ariel Layag’s death on July 30, 2015, prior to the promulgation of the Resolution.
This prompted the Supreme Court to reopen the case despite the finality of the judgment, pursuant to the doctrine allowing relaxation of the rule of immutability of judgments under special or compelling circumstances.

The death of accused before final conviction extinguishes criminal liability and renders the criminal case dismissible under Article 89(1) of the Revised Penal Code.
The Court cited People v. Egagamao establishing that death pending appeal extinguishes criminal liability and civil liability ex delicto but allows separate civil actions for claims arising from other sources of obligation.

Whether the death of the accused, Ariel Layag, prior to the promulgation of the final decision, extinguishes his criminal liability and warrants dismissal of the criminal cases against him.
Whether the Court may reopen and reconsider its final resolution due to the subsequent knowledge of the accused’s death.
The extent to which civil liability arising from the criminal acts survives the death of the accused.