People vs. Dionaldo

The death of an accused pending appeal of his conviction totally extinguishes criminal liability and civil liability ex delicto pursuant to Article 89 of the Revised Penal Code, rendering any judgment rendered thereafter ineffectual as to the deceased and requiring dismissal of the criminal case against him.

Renato Dionaldo y Ebron was among several accused charged with the special complex crime of Kidnapping for Ransom with Homicide for the abduction and killing of Edwin Navarro. Following their conviction by the Regional Trial Court and affirmation by the Court of Appeals, the accused-appellants elevated their case to the Supreme Court. While the appeal was pending, Renato Dionaldo died in detention at the Bureau of Corrections.

• The Conviction: On July 23, 2014, the Supreme Court rendered a Resolution finding 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. The Court sentenced each to suffer the penalty of reclusion perpetua without eligibility for parole and to pay jointly and severally the amounts of P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages, with interest at six percent per annum from finality until fully paid.
• Motion for Reconsideration: Accused-appellants collectively filed a motion for reconsideration of the July 23, 2014 Resolution.
• Death Pending Appeal: On June 10, 2014, accused-appellant Renato Dionaldo y Ebron died while confined at the Bureau of Corrections, as evidenced by a Certificate of Death. The Bureau of Corrections informed the Supreme Court of this death via letter dated September 16, 2014, which was received by the Court on September 24, 2014.
• Procedural Timeline: Renato Dionaldo's death occurred prior to the promulgation of the July 23, 2014 Resolution, at a time when his appeal was still pending resolution before the Court. The Court denied the motion for reconsideration with finality on September 24, 2014, before taking action on the notice of death.

• Extinction of Criminal Liability: Whether the death of an accused-appellant pending appeal of his conviction totally extinguishes his criminal liability.
• Extinction of Civil Liability ex delicto: Whether the death of an accused-appellant pending appeal also extinguishes his civil liability ex delicto.
• Effect on Judgment: Whether the judgment of conviction rendered by the Supreme Court remains valid and enforceable against the estate of an accused who died before the promulgation of the decision.

• Extinction of Criminal Liability: Criminal liability is totally extinguished by the death of the convict as to personal penalties pursuant to Article 89(1) of the Revised Penal Code. Because Renato Dionaldo died on June 10, 2014, while his appeal was still pending and before the promulgation of the July 23, 2014 Resolution, his criminal liability was totally extinguished.
• Extinction of Civil Liability ex delicto: Death pending appeal extinguishes not only criminal liability but also civil liability ex delicto, following the doctrine established in People v. Amistoso. Consequently, Renato's civil liability arising from the offense was likewise extinguished.
• Effect on Judgment: The July 23, 2014 Resolution and the September 24, 2014 Resolution denying the motion for reconsideration are rendered irrelevant and ineffectual as to Renato Dionaldo because he died before the promulgation of the judgment. Accordingly, the criminal case against him is dismissed.

• Article 89 of the Revised Penal Code (Extinction of Criminal Liability by Death) — Criminal liability is totally extinguished by the death of the convict as to personal penalties; as to pecuniary penalties, liability is extinguished only when the death of the offender occurs before final judgment. The Court applied this provision to hold that death occurring while the appeal is pending extinguishes criminal liability.
• People v. Amistoso Doctrine (Effect of Death Pending Appeal) — The death of the accused pending appeal of his conviction extinguishes his criminal liability, as well as his civil liability ex delicto. This doctrine applies notwithstanding that the appellate court had already rendered its judgment convicting the accused, provided the death occurred before the finality or promulgation of the judgment.

• "As Renato's death transpired before the promulgation of the Court's July 23, 2014 Resolution in this case, i.e., when his appeal before the Court was still pending resolution, his criminal liability is totally extinguished in view of the provisions of Article 89 of the Revised Penal Code..."
• "In People v. Amistoso, the Court explained that the death of the accused pending appeal of his conviction extinguishes his criminal liability, as well as his civil liability ex delicto."
• "Consequently, Renato's death on June 10, 2014 renders the Court's July 23, 2014 Resolution irrelevant and ineffectual as to him, and is therefore set aside."

• People v. Amistoso, G.R. No. 201447, August 28, 2013, 704 SCRA 369 — Controlling precedent establishing that death of the accused pending appeal extinguishes both criminal and civil liability ex delicto; followed and applied to the present case.
• People v. Soria, G.R. No. 179031, February 24, 2014, 717 SCRA 274 — Cited in Amistoso; cited to reinforce the doctrine regarding extinction of liability.

• Article 89(1), Revised Penal Code — States that criminal liability is totally extinguished by the death of the convict as to personal penalties, and as to pecuniary penalties, liability therefor is extinguished only when the death of the offender occurs before final judgment. Applied to hold that Renato's death pending appeal extinguished his criminal liability.

Maria Lourdes P.A. Sereno (Chief Justice, Chairperson), Teresita J. Leonardo-De Castro, Lucas P. Bersamin, Jose Portugal Perez, and Estela M. Perlas-Bernabe.

None.