Case Summary (G.R. No. 197252)
Applicable Law
The decision is guided by the 1987 Philippine Constitution, particularly regarding the implications of a defendant's death on criminal and civil liabilities as provided under Article 89 of the Revised Penal Code.
Overview of the Case
The Court of Appeals had found accused-appellants Wenlito and Lolito guilty of murder as defined in Article 248 of the Revised Penal Code. A resolution on June 15, 2016, modified the appellate court's decision, imposing civil liabilities on the accused-appellants to the heirs of the victim, Anatolio Calumba, Jr.
Death of Accused and Legal Implications
Lolito Depillo was reported to have passed away on March 16, 2015, prior to the resolution of the case. This raised crucial legal questions regarding the continuation of his criminal liability and the associated civil liabilities considering that under Article 89 (1) of the Revised Penal Code, criminal liability is extinguished upon the death of the accused before final judgment. The ruling held that both his criminal liability and civil liability grounded solely in the offense were extinguished due to his death.
Civil Liability After Death
Despite the extinguishment of civil liability ex delicto due to Lolito's death, the Court cited precedents indicating that civil liability could survive if founded on sources other than delicts—like law or contracts as defined in Article 1157 of the Civil Code. The ruling emphasized that victims retain the right to seek civil recovery not solely reliant on the criminal action, potentially through the estate of the deceased.
Separate Civil Actions Post-Death
For civil actions arising from the crime, the Court clarified that a victim could file a separate civil suit against the estate of a deceased accused, independent of the criminal proceedings, aligning with procedural rules under the Rules on Criminal Procedure. Furthermore, the statute of limitations on civil claims would be interrupted during the pendency of the criminal action, thereby protecting the victim's rights.
Review of the Finality of Judgment
The Court recognized the pri
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Case Overview
- The case involves the appeal of Wenlito Depillo y Biorco @ "Wewen" and Lolito Depillo y Dehijido @ "Lito" against their conviction of murder.
- The Supreme Court, in a Resolution dated June 15, 2016, affirmed the decision of the Court of Appeals dated October 28, 2010, which found the accused-appellants guilty beyond reasonable doubt of murder under Article 248 of the Revised Penal Code.
Dispositive Portion of the Resolution
- The Court modified the previous decision by ordering the accused-appellants to pay the heirs of the victim, Anatolio Calumba, Jr., various amounts as damages:
- P75,000.00 as civil indemnity
- P75,000.00 as moral damages
- P75,000.00 as exemplary damages
- P50,000.00 as temperate damages
- An interest of 6% per annum was mandated on each item of civil liability from the date of finality of the Resolution until fully paid.
- The accused-appellants were also ordered to pay the costs of the suit.
Death of Accused
- It was revealed that Lolito Depillo y Dehijido had died on March 16, 2015, prior to the resolution of the case.
- The Court addressed the implications of Lolito's death during the pendency of the criminal case, specifically regarding the extinguishment of his criminal liability.
Legal Principles Involved
- Article 89 (1) of th