Case Summary (G.R. No. 175784)
Case Background and Charges
On September 21, 2001, Jaime Ayochok was charged with murder by Prosecutor Benedicto T. Carantes. The Amended Information indicated that on July 15, 2001, in Baguio City, Ayochok, armed with a gun, treacherously shot the victim multiple times while the latter was in a vulnerable position, leading to his death from hypovolemic shock due to massive hemorrhage and multiple gunshot wounds. Ayochok pleaded not guilty upon arraignment.
Trial Court Proceedings
The Regional Trial Court (RTC) of Baguio City rendered a Decision on August 13, 2003, finding Ayochok guilty of murder under Article 248 of the Revised Penal Code. He was sentenced to reclusion perpetua and ordered to pay various indemnities to the victim's heirs totaling substantial amounts, along with the costs of the proceedings. Ayochok was incarcerated at the New Bilibid Prison starting October 31, 2003.
Court of Appeals Review
The case was subsequently elevated to the Court of Appeals (CA) as per the modified provisions of the Revised Rules on Criminal Procedure. On June 28, 2005, the CA affirmed the RTC's ruling with modifications, particularly reducing the civil indemnities owed by Ayochok. Ayochok initially filed a Motion for Reconsideration but later withdrew it, opting instead to appeal directly.
Developments Leading to Death
Attempts to appeal continued through various resolutions by the Court of Appeals. However, the appellate process was interrupted by Jaime Ayochok's death on January 15, 2010, while still imprisoned. Following his death, the Court directed the Bureau of Corrections to provide a certified death certificate, which was submitted on June 22, 2010.
Legal Implications of Death on Criminal Liability
Ayochok's death raised significant legal questions concerning the implications on his criminal and civil liabilities. According to Article 89(1) of the Revised Penal Code, the death of an accused extinguishes personal criminal liability and, in cases where the death occurs before final judgment, also extinguishes pecuniary penalties based solely on the offense.
Extinguishment of Criminal Liability
Referencing precedents such as People v. Bayotas, the Court noted that Ayochok's death extinguished both his criminal liability and civil liability arising solely from the crime charged. The guidelines established in previous rulings clarify that while criminal liability ceases with the accused's death, civil liabilities can survive if based on other obligations not lim
...continue readingCase Syllabus (G.R. No. 175784)
Case Background
- This case revolves around the appeal filed by Jaime Ayochok y Tauli (Ayochok) against the June 28, 2005 Decision of the Court of Appeals (CA-G.R. CR No. 00949).
- The Court of Appeals affirmed with modifications the Regional Trial Court (RTC) of Baguio City’s August 13, 2003 Decision in Criminal Case No. 18658-R, which found Ayochok guilty of Murder.
- The murder charge was based on the incident that occurred on July 15, 2001, where Ayochok allegedly shot SPO1 Claudio Caligtan multiple times while the latter was unable to defend himself.
Charges and Proceedings
- Ayochok was formally charged in an Amended Information dated September 21, 2001, with Murder, stating that he acted with treachery, evident premeditation, and cruelty.
- Upon arraignment, Ayochok pleaded not guilty, leading to a trial on the merits.
- The RTC found Ayochok guilty of Murder under Article 248 of the Revised Penal Code and sentenced him to reclusion perpetua, alongside various financial indemnities to the victim's heirs.
Court Decisions
The RTC's decision included:
- Imprisonment for life.
- Civil indemnity of P75,000.00.
- Moral damages of P200,000.00.
- Actual damages amounting to P378,956.50.
- Unpaid income totaling P2,573,096.40.
- Ayochok was credited for 4/5 of his preventive imprisonment.
Ayochok