Case Digest (G.R. No. 229943)
Facts:
People of the Philippines v. Edgar Robles, et al., G.R. No. 229943, March 18, 2019, Special Second Division, Perlas-Bernabe, J., writing for the Court. The prosecution in Criminal Case No. 1690-LS before the Regional Trial Court (RTC) of Surallah, South Cotabato, Branch 26, charged several respondents, including Edgar Robles and Wilfredo Robles, with the murder of Dan Elvie Sioco. The Court of Appeals (CA) in CA-G.R. CR HC No. 01430 issued a Decision dated November 29, 2016 (penned by Associate Justice Edgardo T. Lloren, with Associate Justices Rafael Antonio M. Santos and Ruben Reynaldo G. Roxas concurring) finding Edgar and Wilfredo guilty beyond reasonable doubt of Murder.The Supreme Court initially adopted the CA Decision in a Resolution dated November 19, 2018, affirming with modification the CA's findings and sentencing Edgar and Wilfredo each to reclusion perpetua and ordering them to pay specified civil, moral, exemplary and temperate damages (with legal interest) to the heirs of the victim. Before an Entry of Judgment could be issued, counsel for the accused-appellants notified the Court by a Notice of Death dated January 4, 2019 that Edgar Robles had died on December 15, 2018, supported by a Certificate of Death.
Confronted with Edgar’s intervening death prior to the finality of the Court’s judgment, the Supreme Court reconsidered its November 19, 2018 Resolution and, applying Article 89 of the Revised Penal Code and the Court’s prior decision in People v. Culas (G.R. No. 211166, June 5, 2017), resolved to modify its earlier Resolution by dismissing the criminal case against Edgar and declaring the case closed and terminated as to him. The modification and term...(Pro-only)
Issues:
- Does the death of accused Edgar Robles prior to final conviction extinguish his criminal liability and warrant dismissal of the criminal case against him?
- Does any civil liability established in the criminal proceedings survive Edgar's death, and if so, by what procedures may the h...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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