Case Summary (G.R. No. 229722)
Applicable Law
The case is governed by the Revised Penal Code of the Philippines, specifically Article 248 concerning murder, as amended by Republic Act No. 7659, and the relevant provisions concerning the effects of death on criminal liability under the Revised Penal Code and the Civil Code.
Factual Background
Accused-appellant de Chavez, alongside co-accused Manolito, was charged with murder following an incident on February 14, 2000, where they allegedly attacked and fatally stabbed Virgilio A. Matundan in Barangay Lipahan, San Juan, Batangas. While co-accused Manolito was arrested, de Chavez initially evaded capture. After Manolito's death prior to trial, the case against him was dismissed, and de Chavez’s case was suspended until his arrest on March 17, 2005. Ultimately, after trial proceedings, de Chavez was convicted of murder by the Regional Trial Court.
Decisions of the Lower Courts
The RTC issued its judgment on November 22, 2012, finding de Chavez guilty beyond reasonable doubt of murdering Matundan and sentenced him to reclusion perpetua along with various monetary damages to the victim's heirs. The Court of Appeals then affirmed this decision on June 29, 2016, which prompted de Chavez to file a final appeal.
Subsequent Developments
While the appeal was pending, de Chavez died on December 9, 2016. This significant development necessitated a reconsideration of the ongoing case as it directly related to the deceased’s criminal and civil liabilities.
Legal Implications of Death
Under Paragraph 1, Article 89 of the Revised Penal Code, the death of the accused prior to final judgment extinguishes both criminal and pecuniary liabilities. The ruling from People v. Bayotas establishes that while the death of the accused eliminates criminal liability, any civil liabilities may persist if they arise from obligations beyond the criminal act itself. Such claims can be pursued through a separate
...continue readingCase Syllabus (G.R. No. 229722)
Case Background
- The case involves an appeal by accused-appellant Dionisio de Chavez, Jr. y Escobido contesting a decision from the Court of Appeals dated June 29, 2016.
- Dionisio de Chavez and his co-accused, Manolito de Chavez, were charged with murder under Article 248 of the Revised Penal Code as amended by Republic Act No. 7659.
- The incident occurred on February 14, 2000, at approximately 5:15 PM in Barangay Lipahan, Municipality of San Juan, Batangas, wherein the accused attacked and fatally stabbed the victim, Virgilio A. Matundan, using a balisong knife.
Procedural History
- An Information was filed on April 17, 2000, charging both accused with murder.
- Co-accused Manolito de Chavez was arrested while Dionisio initially evaded capture.
- Following pre-trial proceedings, Manolito passed away, leading to the dismissal of the case against him and the archival of the case against Dionisio, who remained at large.
- Dionisio was arrested on March 17, 2005, leading to the revival of his case.
- The Regional Trial Court (RTC) of Rosario, Batangas, Branch 87, rendered a decision on November 22, 2012, finding Dionisio de Chavez guilty beyond reasonable doubt of murder.
RTC Decision
- The RTC sentenced Dionisio de Chavez to suffer the penalty of reclusion perpetua, including all accessory penalties as mandated by law.
- The court also ordered him to pay the heirs of