G.R. No. 229943 - People vs. Robles

The case involves People of the Philippines as the plaintiff-appellee and several accused, namely Edgar Robles, Wilfredo Robles, Rolando Robles alias “Bebot,” Dante Aron (deceased), Danilo Robles alias “Toto,” and Jose Robles (deceased).
The Special Second Division of the Supreme Court rendered a resolution on March 18, 2019, adopting and modifying a Decision of the Court of Appeals dated November 29, 2016.

The Court of Appeals found accused-appellants Edgar Robles and Wilfredo Robles guilty beyond reasonable doubt of the crime of Murder, which is defined and penalized under Article 248 of the Revised Penal Code.
Both accused were sentenced to reclusion perpetua.
In addition to the penal sentence, the decision imposed civil liabilities for several monetary awards to be paid solidarily to the heirs of [Dan Elvie] Sioco, namely:

All monetary awards were ordered to accrue interest at the legal rate of six percent per annum from the date of finality of the resolution until full payment.

Before the issuance of the Entry of Judgment, the Court received a Notice of Death (dated January 4, 2019) from the counsel of the accused-appellants.
The notice indicated that Edgar Robles died on December 15, 2018, as corroborated by the attached Certificate of Death.
Under prevailing law and jurisprudence, notably Article 89 (1) of the Revised Penal Code, the death of an accused prior to final conviction renders the criminal case against him dismissible.

Article 89 of the Revised Penal Code was applied, which states that criminal liability is totally extinguished by the death of the convict prior to final judgment with respect to pecuniary penalties.
People v. Culas was cited as a leading case explaining that the death of an accused pending appeal terminates both criminal and civil liability based solely on the offense (civil liability ex delicto in senso strictiore).
The decision also refers to Article 1157 of the Civil Code, which enumerates other sources for obligations (such as law, contracts, quasi-contracts, and quasi-delicts) that may support surviving civil liability independent of the criminal proceeding.

Whether the death of accused-appellant Edgar Robles prior to final conviction extinguishes his criminal liability for the crime of Murder.

Consideration of Article 89 of the Revised Penal Code in determining if criminal liability is automatically nullified upon death before final judgment.
Examination of the implications of People v. Culas regarding the termination of both criminal and pecuniary liabilities based solely on the criminal offense upon the accused’s death.

Whether the civil liability arising from the criminal act is also extinguished by the death of the accused.

Analyzing if the civil action for recovery attached to the criminal action should automatically be dismissed upon Edgar Robles’ death.
Determining if any surviving civil liability might be pursued separately based on sources of obligation other than the criminal delict, as enumerated in Article 1157 of the Civil Code.

The appropriate procedural outcome regarding the criminal case pending against Edgar Robles.

Whether the case should be modified to dismiss the criminal action due to the supervening death of the accused.
The procedure for subsequent civil actions, if any, against Edgar Robles’ estate.