Case Summary (G.R. No. 208651)
Case Proceedings and Decisions
The Supreme Court, in a resolution dated April 7, 2014, affirmed the prior Decision of the Court of Appeals (CA) rendered on December 7, 2012, which found the accused-appellant guilty beyond a reasonable doubt of the crime of rape, as defined under Article 266-A in relation to Article 266-B of Republic Act No. 8353. The resolution sentenced the accused-appellant to reclusion perpetua and mandated him to pay civil indemnity, moral damages, and exemplary damages to the private complainant. It is significant to note that before the promulgation of this resolution, the accused-appellant had passed away on December 28, 2013.
Extinguishment of Criminal Liability
Pursuant to Philippine law and established jurisprudence, the death of the accused prior to final judgment results in the extinguishment of the criminal case against him. This principle is enshrined in Article 89(1) of the Revised Penal Code, which states that criminal liability is totally extinguished by the death of the convict, particularly as it pertains to personal penalties. The Supreme Court’s previous rulings such as in People v. Culas elucidate that both criminal and civil liabilities based on the criminal action cease upon the death of the accused pending appeal.
Civil Liabilities Following Death
The Court differentiated between criminal liability and civil liability. While the claim for civil liability predicated solely on the criminal act is extinguished with the accused's death, civil liability may survive if it is founded on sources other than delict. Article 1157 of the Civil Code specifies that obligations can arise from law, contracts, quasi-contracts, and quasi-delicts. Therefore, if the civil obligation is based on such sources, the offended party, in this case, AAA, has the option to pursue separate civil action against the estate of the deceased accused-appellant.
Separate Civil Actions and Legal Protections
Upon extinguishment of the criminal case, any surviving civil action must be pursued through a distinct civil suit, adhering to procedural rules outlined in Section 1, Rule 111 of the 1985 Rules on Criminal Procedure. It is critical for the offended party to know that initiating a civil acti
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Case Overview
- The case involves the People of the Philippines as the plaintiff-appellee against accused-appellant Romeo Antido y Lantayan, also known as Romeo Antigo y Lantayan and alias "Jon-Jon".
- The decision was rendered by the Special Second Division of the Supreme Court of the Philippines on March 14, 2018.
- The Court affirmed the decision of the Court of Appeals (CA) which had earlier found the accused guilty beyond reasonable doubt of the crime of Rape.
Background and Procedural History
- On December 7, 2012, the Court of Appeals issued a decision finding the accused guilty of rape, punishable under paragraph 1 of Article 266-A in relation to paragraph 5 of Article 266-B of Republic Act (RA) 8353.
- The accused was sentenced to reclusion perpetua and ordered to pay civil indemnity, moral damages, and exemplary damages to the private complainant.
- Prior to the promulgation of the Supreme Court's resolution, it was established that the accused had passed away on December