G.R. No. 214875 - People vs. Layag

Case Summary (G.R. No. 214875)

Factual Background

The accused had been criminally charged before the Regional Trial Court of Marikina City, Branch 156, in four criminal cases numbered 2007-9591-MK to 2007-9594-MK for offenses against a victim identified as AAA. The Court of Appeals, in a Decision dated January 29, 2014, found the accused guilty beyond reasonable doubt of one count of Qualified Rape by Sexual Intercourse under Article 266-A paragraph 1 in relation to Article 266-B(1) of the Revised Penal Code, two counts of Qualified Rape by Sexual Assault under paragraph 2, Article 266-A in relation to Article 266-B(1), and one count of Acts of Lasciviousness under Article 336 of the Revised Penal Code. The CA prescribed imprisonment and ordered civil, moral, and exemplary damages in specified amounts for each count.

Trial and Appellate Disposition Prior to Reopening

The Supreme Court initially adopted the findings and conclusions of the Court of Appeals in a Resolution dated August 3, 2015, affirming the convictions and the monetary awards as modified by the CA. An Entry of Judgment was filed on October 14, 2015 declaring the Resolution final and executory. The convictions thus became formally affirmed and the monetary awards became judgment obligations as of that Entry.

Post-Promulgation Development and Notice of Death

The Supreme Court received on July 18, 2016 a letter from the Bureau of Corrections attaching a Certificate of Death showing that the accused had died on July 30, 2015. The Certificate indicated that the accused’s death had occurred prior to the promulgation of the Supreme Court’s August 3, 2015 Resolution, a fact of which the Court was belatedly informed. This post-Entry information prompted the Court to revisit the matter despite the prior finality of its Resolution.

The Court’s Authority to Reopen Final Judgments

The Court invoked the principle permitting relaxation of the immutability of judgment where special or compelling circumstances exist. The Court cited Bigler v. People, G.R. No. 210972, March 19, 2016, for the test that may justify reopening a final judgment. The factors adverted to included the presence of matters affecting life, liberty, honor, or property; the existence of special or compelling circumstances; consideration of the merits; that the cause for reopening be not entirely attributable to the fault or negligence of the party favored by the judgment; absence of a showing that the sought review was frivolous or dilatory; and that the other party would not be unjustly prejudiced.

Legal Effect of Death on Criminal and Civil Liability

The Court applied Article 89(1) of the Revised Penal Code, which provides that criminal liability is totally extinguished by the death of the convict as to personal penalties, and that pecuniary penalties are extinguished only when death occurs before final judgment. The Court relied on People v. Egagamao, G.R. No. 218809, August 3, 2016, which the Court summarized into discrete propositions: (1) death of an accused pending appeal extinguishes his criminal liability and the civil liability based solely thereon (ex delicto in senso strictiore); (2) civil liability that may be predicated on sources other than delict survives; (3) where civil liability survives a separate civil action may be filed and enforced against the executor, administrator, or estate as appropriate pursuant to Section 1, Rule 111 of the 1985 Rules on Criminal Procedure; and (4) prescription need not be feared where the private offended party had filed a civil action during the criminal prosecution because the statute of limitations is interrupted during the pendency of the criminal case pursuant to Article 1155 of the Civil Code.

Application of Law to the Present Case

The Court found that the accused had died on July 30, 2015, before the promulgation of the Supreme Court’s Resolution dated August 3, 2015, and therefore prior to final judgment. This chronological fact constituted the special and compelling circumstance that warranted relaxation of the immutability doctrine and reopening of the final Resolution. Under Article 89(1) and the principles articulated in People v. Egagamao, the Court concluded that the criminal liability of the accused had been extinguished by death and that the civil liabilities arising solely from the criminal convictions were likewise ipso facto extinguished.

Disposition and Orders

The Court set aside its Resolution dated August 3, 2015. It dismissed Crim. Case Nos. 2007-9591-MK, 2007-9592-MK, 2007-9593-MK, and 2007-9594-MK before the Regional Trial Court

Case Syllabus (G.R. No. 214875)

Parties and Procedural Posture

PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE prosecuted criminal actions originally filed in the Regional Trial Court of Marikina City, Branch 156.
ARIELLAYAG ACCUSED-APPELLANTS was the accused in four criminal cases docketed as Crim. Case Nos. 2007-9591-MK, 2007-9592-MK, 2007-9593-MK, and 2007-9594-MK.
The Court adopted in toto the Court of Appeals Decision dated January 29, 2014 by Resolution dated August 3, 2015 and later issued an Entry of Judgment dated October 14, 2015 declaring that the Resolution had become final and executory.
The Court later received a letter dated July 18, 2016 from the Bureau of Corrections informing the Court of the death of ARIELLAYAG on July 30, 2015, supported by a Certificate of Death.

Key Factual Allegations

The accused was found by the Court of Appeals to have committed one count of Qualified Rape by Sexual Intercourse and two counts of Qualified Rape by Sexual Assault against the victim identified as AAA.
The accused was likewise found to have committed one count of Acts of Lasciviousness against the said victim.
The factual findings of the Court of Appeals were expressly adopted by the Court in its August 3, 2015 Resolution.

Procedural History

The Court of Appeals rendered its decision on January 29, 2014, convicting the accused as to the enumerated offenses.
The Court adopted the Court of Appeals Decision by its August 3, 2015 Resolution and subsequently declared that Resolution final and executory in an Entry of Judgment dated October 14, 2015.
The Court was belatedly informed by the Bureau of Corrections via a July 18, 2016 letter that the accused died on July 30, 2015, which preceded the promulgation of the August 3, 2015 Resolution.

Convictions and Penalties

The accused was adjudged guilty of one count of Qualified Rape by Sexual Intercourse under Article 266-A paragraph 1 in relation to Article 266-B (1) of the Revised Penal Code and was sentenced to suffer reclusion perpetua without eligibility for parole, and ordered to pay P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages.
The accused was adjudged guilty of two counts of Qualified Rape by Sexual Assault under paragraph 2, Article 266-A in relation to Article 266-B (1) of the Revised Penal Code and was sentenced to suffer imprisonment for the indeterminate period of eight years and one day of prision mayor, as minimum, to seventeen years of reclusion temporal, as maximum, and ordered to pay P30,000.00 as civil indemnity, P30,000.00 as moral damages, and P30,000.00 as exemplary damages for each count.
The accused was adjudged guilty of one count of Acts of Lasciviousness under Article 336 of the Revised Penal Code and was sentenced to suffer imprisonment for the indeterminate period of six months of arresto mayor, as minimum, to four years and two months of prision correccional, as maximum, and ordered to pay P20,000.00 as civil indemnity, P30,000.00 as moral damages, and P30,000.00 as exemplary damages.
All monetary awards were ordered to earn legal interest of six percent per annum from the date of finality of the August 3, 2015 Resolution until full payment.

Post-Judgment Events

The Bureau of Corrections letter dated July 18, 2016 advised the Court that the accused died on July 30,