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PEOPLE v. PORFERIO CULAS Y RAGA

FACTS:

The case involves the appeal of accused-appellant Porferio Culas y Raga (accused-appellant) who was found guilty beyond reasonable doubt of the crime of statutory rape by the Court of Appeals (CA) in CA-G.R. CEB-CR HC No. 00380. The accused-appellant was sentenced to reclusion perpetua without eligibility for parole and ordered to pay civil indemnity, moral damages, and exemplary damages. However, before an Entry of Judgment could be issued, the Court received a Letter from the Bureau of Corrections stating that the accused-appellant had already passed away on February 8, 2014. In light of the accused-appellant's death, the Court decided to reconsider and set aside its previous Resolution, dismissing the criminal case against him. The Court cited Article 89(1) of the Revised Penal Code, which provides that criminal liability is totally extinguished by the death of the accused. It also reiterated the ruling in People v. Layag, which states that the death of the accused pending appeal of his conviction extinguishes his criminal liability and only the civil liability directly arising from the offense committed. It further explained that the civil liability may still be pursued through a separate civil action against the executor/administrator or the estate of the accused, depending on the source of obligation upon which it is based. Consequently, the Court dismissed the criminal case against the accused-appellant, declaring the case closed and terminated.

ISSUES:

  1. Whether the death of the accused-appellant prior to his final conviction renders the criminal case against him dismissible.

  2. Whether the civil liability of the accused-appellant survives despite his death.

RULING:

  1. Yes, the death of the accused-appellant prior to his final conviction renders the criminal case against him dismissible. Under Article 89(1) of the Revised Penal Code, criminal liability is totally extinguished by the death of the convict, as to the personal penalties. In the case of People v. Layag, the Supreme Court ruled that the death of the accused pending appeal of his conviction extinguishes his criminal liability.

  2. Yes, the civil liability of the accused-appellant survives despite his death. The claim for civil liability may be based on sources other than the offense committed, such as law, contracts, quasi-contracts, quasi-delicts, among others. Thus, the private offended party may still file a separate civil action against the estate of the accused-appellant, depending on the source of obligation upon which the civil liability is based.

PRINCIPLES:

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

  • The claim for civil liability survives notwithstanding the death of the accused, if it may also be predicated on a source of obligation other than the offense committed.

  • The separate civil action for recovery of civil liability may be pursued either against the executor/administrator or the estate of the accused, depending on the source of obligation upon which it is based.

  • The statute of limitations on the civil liability is deemed interrupted during the pendency of the criminal case if the private offended party instituted the civil action together with the criminal action.