Case Summary (G.R. No. 229856)
Conviction and Sentencing
The RTC, after a thorough trial, issued a decision on March 11, 2015, wherein it found Calomia guilty beyond a reasonable doubt of two counts of qualified rape. As a result of his relationship with the victim and the nature of the crimes, the court imposed the penalty of reclusion perpetua for each count, as the death penalty was prohibited by Republic Act No. 9346. Furthermore, the court awarded the victim civil indemnity, moral damages, and exemplary damages, allocating specific amounts as established by precedent.
Appeal to the Court of Appeals
Following his conviction, Calomia appealed to the Court of Appeals, which was docketed as CA-G.R. CEB-CR-HC No. 02040. On August 26, 2016, the appellate court affirmed the RTC’s decision but modified the damage awards to AAA, increasing the amounts for civil indemnity, moral damages, and exemplary damages to P100,000 each. The appellate court also imposed interest on the damages at a rate of 6% per annum until fully paid.
Circumstances of Death
On September 21, 2016, Calomia filed a notice of appeal to the Supreme Court. However, it was subsequently revealed through a letter dated August 2, 2017, from Jail Chief Inspector Felipe A. Montejo that Calomia had died on September 29, 2015, due to asphyxia resulting from self-inflicted strangulation while confined at the Bohol District Jail.
Legal Effect of Death on Criminal Liability
According to Article 89 of the Revised Penal Code, the death of an accused extinguishes both criminal and civil liability ex delicto, provided the death occurs before final judgment. The Supreme Court, referencing the precedent established in People v. Bayotas, affirmed that the death of Calomia prior to the finality of his conviction extinguished both his criminal liabilities and civil liabilities directly linked to the offenses he committed. Therefore, his death rendered the conviction and subsequent decisions ineffectual.
Conclusion and Dismiss
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Case Background
- The case involves accused-appellant Ruben Calomia, who was charged in Criminal Case Nos. 1317 and 1318 in the Regional Trial Court (RTC) of Loay, Bohol, Branch 50.
- The charges were two counts of qualified rape against his minor daughter, referred to as AAA, alleged to have occurred in August 2007 and April 2008.
- The RTC conducted a trial and issued its Decision on March 11, 2015, finding Calomia guilty beyond a reasonable doubt.
RTC Decision
- The RTC found Calomia guilty of:
- Qualified Incestuous Rape in Criminal Case No. 1317.
- Statutory Incestuous Rape in Criminal Case No. 1318.
- The penalty imposed was reclusion perpetua for each count due to the prohibition of the death penalty under R.A. No. 9346.
- The court also awarded civil indemnity, moral damages, and exemplary damages to the victim AAA:
- P75,000 for civil indemnity per count.
- P75,000 for moral damages per count, referencing People v. Lauga.
- P30,000 for exemplary damages per count.
Court of Appeals Ruling
- Accused-appellant appealed the RTC's decision, which was heard in the Court of Appeals, docketed as CA-G.R. CEB-CR-HC No. 02040.
- On August 26, 2016, the Court of Appeals upheld Calomia's conviction but modified the damage awards:
- P100,000 as civil indemnity.
- P100,000 as moral damages.
- P100,000 as exemplary damages.
- Interest was imposed on all damages at 6% per annum from the date of fin