G.R. No. 207949 - People vs. Dionaldo y Ebron

Case Summary (G.R. No. 207949)

Procedural History and Disposition by the Court

The Court rendered a Resolution dated July 23, 2014 affirming the Court of Appeals Decision of February 15, 2013 (CA-G.R. CR-H.C. No. 02888) with modification: all accused-appellants were found guilty beyond reasonable doubt of the special complex crime of Kidnapping for Ransom with Homicide. Each was sentenced to reclusion perpetua without eligibility for parole, and ordered to pay jointly and severally to the family of Edwin Navarro P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages, all with 6% interest per annum from finality until fully paid. The accused-appellants collectively moved for reconsideration, which the Court denied by a Resolution dated September 24, 2014.

Intervention by the Bureau of Corrections and Proof of Death

On September 24, 2014, the Court received a letter from the Bureau of Corrections dated September 16, 2014, informing the Court of the death of accused-appellant Renato on June 10, 2014. The letter was accompanied by a Certificate of Death (including its dorsal portion) as evidence of Renato’s demise.

Legal Basis for Extinguishment of Liability (Applicable Law)

Applicable constitutional framework: the 1987 Philippine Constitution. Applicable penal law: Article 89 of the Revised Penal Code. Article 89 provides that criminal liability is totally extinguished (1) by the death of the convict as to personal penalties; and (2) as to pecuniary penalties, liability for them is extinguished only when the death of the offender occurs before final judgment.

Precedential Authority Applied

The Court relied on its prior decision in People v. Amistoso (G.R. No. 201447, Aug. 28, 2013), which the Court summarized as holding that the death of an accused pending appeal of his conviction extinguishes his criminal liability as well as his civil liability ex delicto. The Court cited the same principle in People v. Soria (G.R. No. 17903L, Feb. 24, 2014).

Application of Law to the Facts

Because Renato died on June 10, 2014 — before the Court promulgated its July 23, 2014 Resolution and while his appeal before the Court was still pending — his criminal liability was deemed totally extinguished under Article 89. The Court applied the Amistoso precedent to conclude

Case Syllabus (G.R. No. 207949)

Case Title and Source

Reported at 769 Phil. 555, First Division, G.R. No. 207949, September 09, 2015.
Caption identifies the People of the Philippines as plaintiff-appellee and Armando Dionaldo y Ebron, Renato Dionaldo y Ebron, Mariano Gariguez, Jr. y Ramos, and Rodolfo Larido y Ebron as accused-appellants.
The Resolution in the record is authored by Justice Perlas-Bernabe and includes concurrence by Chief Justice Sereno (Chairperson), and Justices Leonardo-De Castro, Bersamin, and Perez.

Procedural Posture and Chronology

The Court rendered a Resolution on July 23, 2014 finding the accused-appellants guilty beyond reasonable doubt of the special complex crime of Kidnapping for Ransom with Homicide (referenced in the record at Rollo, pp. 59-68).
The dispositive portion of the July 23, 2014 Resolution affirmed the Court of Appeals Decision dated February 15, 2013 in CA-G.R. CR-H.C. No. 02888, with a specified modification.
The accused-appellants collectively moved for reconsideration of the July 23, 2014 Resolution (recorded at Rollo, pp. 69-75).
The Court denied the motion for reconsideration in a Resolution dated September 24, 2014 (recorded at Rollo, p. 76-A).
On September 16, 2014, the Court received a letter from the Bureau of Corrections informing the Court of the death of accused-appellant Renato on June 10, 2014, with an attached Certificate of Death (letter at Rollo, p. 77; certificate at Rollo, p. 78, including its dorsal portion).

July 23, 2014 Resolution — Findings and Disposition

The July 23, 2014 Resolution found accused-appellants Armando Dionaldo y Ebron, Renato Dionaldo y Ebron, Mariano Gariguez, Jr. y Ramos, and Rodolfo Larido y Ebron guilty beyond reasonable doubt of the special complex crime of Kidnapping for Ransom with Homicide (Rollo, pp. 59-68).
The Court dismissed the appeal and affirmed the Court of Appeals Decision dated February 15, 2013 in CA-G.R. CR-H.C. No. 02888 with a modification as to the collective guilt of the accused-appellants.

Sentences, Penalties, and Monetary Awards Imposed in the July 23, 2014 Resolution

All the accused-appellants were equally found guilty of the special complex crime of Kidnapping for Ransom with Homicide.
Each was sentenced to suffer the penalty of reclusion perpetua, without eligibility for parole.
Each was ordered to pay, jointly and severally, to the family of the kidnap victim Edwin Navarro:
- (1) P100,00.00 as civil indemnity;
- (2) P100,000.00 as moral damages;
- (3) P100,000.00 as exemplary damages.
All monetary awards were ordered to bear interest at the rate of six percent (6%) per annum from the date of finality of judgment until fully paid.
The dispositive portion concluded with the directive “SO ORDERED.” (Rollo, pp. 59-68).

Motion for Reconsideration and Denial

The accused-appellants filed a collective motion for reconsideration of the July 23, 2014 Resolution (Rollo, pp. 69-75).
The Court issued a Resolution dated September 24, 2014 denying the motion for reconsideration with finality (Rollo, p. 76-A).

Notice of Death of Accused-Appellant Renato

On September 16, 2014 the Bureau of Corrections sent a letter to the Court informing it of the