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PEOPLE v. PAUL ANDERSON Y JEFFREY

FACTS:

Accused-appellant Paul Anderson y Jeffrey (Anderson) was found guilty by the Court of Appeals (CA) of two counts of Rape by Sexual Assault and Acts of Lasciviousness. The Court affirmed the CA's decision on April 26, 2017, thereby upholding Anderson's conviction. However, in a Manifestation and Undertaking with Motion to Dismiss, Anderson's counsel informed the Court that Anderson had already died on April 21, 2007. This means that Anderson had already passed away during the pendency of the criminal case against him. The defense argued that under Article 89(1) of the Revised Penal Code, criminal liability is extinguished by the death of the accused, and thus, the criminal case against Anderson should be dismissed. The Court clarified that while the criminal case is extinguished, the victim may still file a separate civil action against Anderson's estate based on sources other than delicts. Therefore, considering Anderson's death prior to his final conviction, the Court set aside its earlier resolution and dismissed the criminal case against him.

ISSUES:

  1. Whether the death of the accused prior to his final conviction should result in the dismissal of the criminal case against him.

  2. Whether the civil action based on the delict is also extinguished by the death of the accused.

RULING:

  1. Yes. The death of the convict extinguishes his criminal liability, as provided in Article 89(1) of the Revised Penal Code. However, for pecuniary penalties, liability is extinguished only when the death of the offender occurs before final judgment. Therefore, since the accused died prior to his final conviction, the criminal case against him should be dismissed.

  2. Yes. The civil action based on the delict is also ipso facto extinguished with the death of the accused. The civil liability arising from the offense is grounded on the criminal action. However, if the civil liability may be based on sources other than delicts, such as laws, contracts, quasi-contracts, or quasi-delicts, the victim may file a separate civil action against the accused's estate.

PRINCIPLES:

  • Death of the accused pending appeal of his conviction extinguishes his criminal liability, as well as the civil liability based solely on the offense committed (civil liability ex delicto in its strictest sense).

  • The claim for civil liability survives if it may be predicated on sources other than delicts, as enumerated in Article 1157 of the Civil Code.

  • The private offended party can pursue a separate civil action for the recovery of civil liability, but this action should be filed in accordance with Section 1, Rule 111 of the 1985 Rules on Criminal Procedure.

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