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LYDIA A. VILLEGAS v. CA

FACTS:

This case originated from a libel suit filed by then Assemblyman Antonio V. Raquiza against then Manila Mayor Antonio J. Villegas, who allegedly publicly imputed to him acts constituting violations of the Anti-Graft and Corrupt Practices Act. Villegas made these imputations on several occasions in August 1968. The Committee on Public Works, after investigation, cleared Raquiza of all charges. On July 25, 1969, an information for libel was filed against Villegas. Villegas then left for the United States where he stayed until his death in 1984. Trial proceeded in absentia, and by the time of Villegas's death, the prosecution had already rested its case. Judge Marcelo R. Obien rendered judgment on March 7, 1985, ordering Villegas's estate to pay Raquiza Two Hundred Million Pesos (P200,000,000.00) in damages. The Heirs of Villegas appealed the decision, questioning the validity of the judgment, the absence of formal substitution of parties, and the justness and reasonableness of the damages awarded. The Court of Appeals affirmed the trial court's judgment, but reduced the award of damages to P2 million. The Heirs and Raquiza both appealed the decision to the Supreme Court. The issue at hand is the effect of the death of Villegas before final judgment on his civil liability.

ISSUES:

  1. Whether the trial court, three months after notice of the death of the accused and before his counsel could file a memorandum in his behalf, could validly render judgment in the case.

  2. Whether, in the absence of formal substitution of parties, the trial court could validly render judgment against the heirs and estate of a deceased accused.

  3. Whether, under the facts of the instant case, deceased Villegas was liable for libel, and assuming he was, whether the damages awarded by the trial court were just and reasonable.

RULING:

  1. The death of the accused before the final judgment extinguished his criminal liability as well as the civil liability based solely thereon. The trial court thus had no jurisdiction to render judgment on the civil aspect of the case against the deceased accused without proper substitution of parties.

  2. In the absence of formal substitution of parties, the judgment rendered by the trial court against the heirs and estate of the deceased accused was invalid.

  3. Given the procedural flaws and the Bayotas ruling, the court did not address whether Villegas was liable for libel or the reasonableness of the damages awarded by the trial court.

PRINCIPLES:

  • Death of the accused pending appeal of his conviction extinguishes his criminal liability as well as the civil liability based solely thereon.

  • Civil liability can survive if it is predicated on sources of obligations other than the delict (e.g., quasi-delicts).

  • In cases where a criminal action is terminated due to the death of the accused, and the civil action was impliedly instituted with the criminal, the offended party may still pursue their claim for damages by filing a separate civil action against the executor or administrator of the deceased’s estate.

  • There must be proper substitution of parties in cases involving the deceased for the court to validly render judgment regarding civil liability.