G.R. No. 223708 - People vs. Monroyo y Mahaguay

The accused-appellant, Norieto Monroyo y Mahaguay, was previously convicted by the Court of Appeals in its Decision dated May 27, 2015 (CA-G.R. CR-H.C. No. 06078).
He was found guilty beyond reasonable doubt of three counts of Acts of Lasciviousness and one count of Qualified Rape.
Specific sentences were imposed:

For Criminal Case Nos. C-04-7785, C-04-7786, and C-04-7787, the accused was sentenced to suffer an indeterminate period of fourteen (14) years and eight (8) months to twenty (20) years of reclusion temporal per count, along with monetary penalties payable to victim AAA (P20,000.00 as civil indemnity, P30,000.00 as moral damages, and P30,000.00 as exemplary damages for each count).
For Criminal Case No. C-04-7788, he was sentenced to reclusion perpetua without eligibility for parole and ordered to pay victim BBB (P100,000.00 each for civil indemnity, moral damages, and exemplary damages).

The monetary awards were mandated to accrue interest at a rate of six percent (6%) per annum from the date of finality of judgment until fully paid.

On June 28, 2017, the Court issued a Decision affirming with modifications the earlier CA ruling, thereby confirming the conviction and sentences against the accused-appellant.
The ruling maintained the criminal liability and penalties imposed, along with the obligation for payment of damages to the victims.

Accused-appellant timely moved for reconsideration; however, subsequent developments altered the context of the case.
On November 23, 2018, Chief Correction Superintendent Richard W. Schwarzkopf, Jr. of the Bureau of Corrections notified the Court that the accused-appellant had died on August 15, 2018.
Death was evidenced by the Death Report from New Bilibid Prison Hospital, signed by Medical Officer Dr. Benevito A. Fontanilla.

The death of the accused-appellant prior to final judgment meant that his criminal liability, as well as the related civil liability based solely on the delict, were subject to extinction.
Prevailing law (Article 89 of the Revised Penal Code) and jurisprudence (as explained in People v. Culas and People v. Layag) set the framework whereby death terminates criminal liability and, in limited cases, civil liability enacted solely upon the criminal offense.
The decision noted that while the criminal liabilities would be dismissed because of the death, surviving civil liabilities based on alternative sources of obligation (law, contracts, quasi-contracts, etc.) might warrant separate civil action against the estate of the deceased.

Whether the death of the accused-appellant prior to the final judgment results in the extinction of his criminal liability and mandates the dismissal of the ongoing criminal cases.

The issue was raised in light of the timely motion for reconsideration, complicated by the subsequent confirmation of the accused-appellant’s death.
The legal query extended to the effect of the death on any related civil liabilities that were solely based on the criminal offense.

The determination of whether separate civil actions might be sustained against the estate depending on the source of obligation for the awards, aside from the extinguished delictual liability.

This involves an analysis of the dual nature of civil liabilities—those arising directly from the criminal act (delict) and those originating from other contractual or statutory obligations.