Case Summary (G.R. No. 45471)
Case Background and Court Proceedings
On July 18, 2014, the Supreme Court adopted the Decision from the Court of Appeals dated July 25, 2013, which affirmed the conviction of Porferio Culas y Raga for statutory rape under the Revised Penal Code. The Court imposed a sentence of reclusion perpetua without parole, alongside civil indemnity and damages. However, before the entry of judgment could be finalized, the Court received notification of the accused's death on February 8, 2014.
Legal Principle on Death of the Accused and Criminal Liability
Under Article 89(1) of the Revised Penal Code, death extinguishes criminal liability. The Court referred to the precedent set in People v. Layag, which specifies that the death of an accused before a final judgment alleviates criminal liability and associated civil liability arising solely from the offense. However, if any civil liability stems from sources other than delict, such claims can survive the accused's death.
Implications for Civil Liability
The ruling delineates that while the criminal case is extinguished upon the accused's death, civil liability could persist if it is based on legal grounds apart from delict. In such scenarios, the offended party, AAA, retains the right to pursue a separate civil action against th
...continue readingCase Syllabus (G.R. No. 45471)
Case Overview
- The case involves the accused-appellant Porferio Culas y Raga, who was found guilty of Statutory Rape by the Court of Appeals in a decision dated July 25, 2013, which was later adopted by the Supreme Court in its Resolution dated July 18, 2014.
- The Supreme Court affirmed the findings of guilt and imposed a penalty of reclusion perpetua without eligibility for parole, alongside civil indemnity and damages.
Judgment and Sentencing
- Affirmation of Guilt: The Supreme Court confirmed the accused-appellant's conviction for Statutory Rape under Article 266-A and Article 266-B (1) of the Revised Penal Code.
- Penalties Imposed:
- Reclusion perpetua without eligibility for parole.
- Civil indemnity of PHP 100,000.00.
- Moral damages amounting to PHP 100,000.00.
- Exemplary damages of PHP 100,000.00.
- Legal interest set at 6% per annum on the monetary awards from the date of finality of the judgment until fully paid.
Accused-Appellant's Death
- The Court received a letter from the Bureau of Corrections on September 16, 2014, stating that the accused-appellant passed aw