Case Digest (G.R. No. 214875)
Facts:
People of the Philippines v. Ariel Layag, G.R. No. 214875, October 17, 2016, First Division, Perlas-Bernabe, J., writing for the Court.The criminal cases arose from charges against Ariel Layag for one count of Qualified Rape by Sexual Intercourse, two counts of Qualified Rape by Sexual Assault, and one count of Acts of Lasciviousness. The Court of Appeals (CA) in CA-G.R. CR-H.C. No. 05383 rendered a Decision dated January 29, 2014 finding Layag guilty beyond reasonable doubt and prescribing penalties and awards of damages. The Supreme Court subsequently issued a Resolution dated August 3, 2015 adopting the CA Decision in toto and modifying the award of damages, and an Entry of Judgment dated October 14, 2015 declared that Resolution final and executory.
After finality, the Supreme Court received a Letter dated July 18, 2016 from the Bureau of Corrections informing the Court that Layag had died on July 30, 2015, supported by a Certificate of Death. Because Layag’s death occurred prior to the promulgation of the August 3, 2015 Resolution, the Court reopened the matter despite the conventional immutability of final judgments. Relying on its prior decision in Bigler v. People, the Court concluded that Layag’s death constituted a special or compelling circumstance justifying relaxation of the doctrine of immutability and re-examination of the final Resolution.
On reconsideration, the Court applied Article 89(1) of the Revised Penal Code and the reasoning in People v. Egagamao, and determined that Layag’s death prior to final conviction extinguished his criminal liability and the civil liability based solely on the criminal action (civil liability ex delicto). The Court therefore set aside its August 3, 2015 Resolution, dismissed the four criminal cases pending before the Regional Trial Court of Marikina City, Branch 156, and declared the c...(Subscriber-Only)
Issues:
- May the Supreme Court reopen and set aside its own final Resolution adopting the CA decision upon belated notice of the accused’s death prior to promulgation?
- Does the death of an accused occurring before final conviction extinguish his criminal liability and the civil liability that is based solely on that criminal action (civil liability ex delicto)?
- If the accused’s death extinguishes civil liability ex delicto, may the private offended party still pursue civil rec...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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