People v. Dionaldo

IV — Effect of Death on Civil Actions

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Case DigestWeek 4 - Rule 111 - Prosecution of Civil Action

People v. Dionaldo

G.R. No. 207949 · September 9, 2015 · First Division

IV — Effect of Death on Civil Actions

Petitioner: People of the PhilippinesRespondent: Armando Dionaldo y Ebron, Renato Dionaldo y Ebron, Mariano Gariguez, Jr. y Ramos, and Rodolfo Larido y Ebron

Core Doctrine

Where several accused are convicted in a single case, the death of one of them, occurring before finality of the judgment as to him, extinguishes only his own criminal liability and ex delicto civil liability, pursuant to Art. 89(1), Revised Penal Code, as construed in Bayotas. This extinguishment is personal to the deceased and has no effect on the criminal and civil liabilities of his co-accused, whose convictions stand independently. A Resolution or Decision that has already become final as to the group of accused collectively may still be set aside as to one member alone upon proof that his death, in fact, preceded that finality — the Court's disposition may selectively apply the extinguishment rule to the deceased co-accused while leaving the judgment undisturbed as to the rest.

ℹ️ Assigned Topic/Subtopic

IV. Effect of Death on Civil Actions

ℹ️ Distinct nuance: death of only one among several co-accused

Unlike most cases in this cluster, this Resolution involves four convicted co-accused, only one of whom (Renato Dionaldo) died pending resolution of the case. The Resolution illustrates that Bayotas's extinguishment rule operates individually, not collectively — the criminal and civil liabilities of the deceased co-accused are extinguished and his case dismissed, while the convictions (and corresponding solidary civil liability) of the surviving co-accused remain fully in force and unaffected.

Facts

Armando Dionaldo y Ebron, Renato Dionaldo y Ebron, Mariano Gariguez, Jr. y Ramos and Rodolfo Larido y Ebron were charged with and convicted of the special complex crime of Kidnapping for Ransom with Homicide arising from the kidnapping and killing of Edwin Navarro.
The RTC convicted all four, and on 15 February 2013 the Court of Appeals affirmed (CA-G.R. CR-H.C. No. 02888).
On 23 July 2014 the Supreme Court affirmed with modification: "all the accused-appellants herein are equally found GUILTY… and are sentenced to each suffer the penalty of reclusion perpetua, without eligibility for parole, and to pay, jointly and severally, the family of the kidnap victim Edwin Navarro… ₱100,000.00 as civil indemnity; ₱100,000.00 as moral damages; and ₱100,000.00 as exemplary damages," with 6% interest from finality.
Their joint motion for reconsideration was denied with finality on 24 September 2014.
On that very date the Court received a letter dated 16 September 2014 from the Bureau of Corrections reporting that Renato Dionaldo had died on 10 June 2014, with his Certificate of Death attached — a month and a half before the 23 July 2014 Resolution. One of four; the other three were alive throughout.
On 9 September 2015 the First Division, through Justice Perlas-Bernabe, set aside both Resolutions and dismissed the case as to Renato alone.

Issue

Where one of several co-accused convicted in a single judgment dies before its promulgation — a fact undisclosed until after both the Resolution and the denial of reconsideration — what is the effect on his own criminal and civil liability, and does it affect his surviving co-accused?

Ruling

RENATO'S LIABILITY EXTINGUISHED; HIS CO-ACCUSED UNAFFECTED. "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." Citing People v. Amistoso: "the death of the accused pending appeal of his conviction extinguishes his criminal liability, as well as his civil liability ex delicto." Hence "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. Accordingly, the criminal case against Renato is dismissed." The convictions and solidary liability of the other three stand undisturbed.

WHEREFORE, the Resolutions dated July 23, 2014 and September 24, 2014 of the Court are hereby SET ASIDE and Criminal Case No. C-68329 before the Regional Trial Court of Caloocan City, Branch 129 is DISMISSED insofar as accused-appellant RENATO DIONALDO y EBRON is concerned, in view of his demise.

SO ORDERED.

Ratio

Article 89(1) applied to Renato alone: his death having preceded the Resolution affirming his conviction, his criminal liability was totally extinguished.
People v. Amistoso supplied the corollary — that extinguishment necessarily carries with it the ex delicto civil liability, the latter being wholly derivative of the former.
The Court limited its disposition textually and deliberately — "as to him" and "insofar as accused-appellant RENATO DIONALDO… is concerned" — ensuring the ruling could not be misread as disturbing the final convictions of the other three.
So the liabilities were treated as legally severable, even though all four had been convicted, sentenced, and held jointly and severally liable in the same Resolution.

Doctrine

Extinguishment by death operates individually, not collectively.

Where one of several co-accused dies before promulgation of the judgment affirming their conviction, his criminal and ex delicto civil liability are extinguished and his case dismissed, while the convictions and civil liability of the surviving co-accused remain fully in force.
Civil liability from non-delictual sources survives as to the deceased and may be pursued by separate action against his estate.

Limits.

Solidarity does not travel with the dismissal. The other three remain jointly and severally liable for the full award — the death removes one obligor from the criminal judgment, it does not reduce the amount recoverable from those who remain.
And the disposition's wording is doing real work: without the "as to him" limitation, setting aside two Resolutions that had affirmed all four convictions could have been read as unsettling the whole judgment.
That drafting care is the practical lesson. Read with People v. Culas and People v. Antido for the single-accused pattern, and note that this case adds the only variable the others lack — plurality of accused. The rule itself is unchanged; only its addressee is narrowed.

Full Digest — Recitation Format

Gist

Classification: DIRECT. This Resolution applies the Bayotas framework's extinguishment rule in the distinct context of a multi-accused conviction, clarifying that death's legal effect is individualized rather than collective — squarely within this Topic.
Armando Dionaldo, Renato Dionaldo, Mariano Gariguez, Jr., and Rodolfo Larido were convicted of the special complex crime of Kidnapping for Ransom with Homicide in connection with the death of kidnap victim Edwin Navarro. On 23 July 2014, the Supreme Court rendered a Resolution affirming their conviction with modification, sentencing each to reclusion perpetua without eligibility for parole and ordering them, jointly and severally, to pay the victim's family ₱100,000 each as civil indemnity, moral damages, and exemplary damages.
The accused collectively moved for reconsideration, which the Court denied with finality in a Resolution dated 24 September 2014. On that same date, the Court received a letter from the Bureau of Corrections, dated 16 September 2014, informing it that co-accused Renato Dionaldo had died on 10 June 2014 — a date before the Court's own 23 July 2014 Resolution affirming the group's conviction.
Applying Art. 89(1), RPC, and People v. Amistoso, the Supreme Court held that Renato's death, having preceded the promulgation of the 23 July 2014 Resolution, totally extinguished his criminal liability as well as his civil liability ex delicto, rendering that Resolution (and the subsequent 24 September 2014 denial of reconsideration) "irrelevant and ineffectual as to him." The Court set aside its prior Resolutions and dismissed the criminal case insofar as Renato Dionaldo alone was concerned — leaving the convictions of Armando Dionaldo, Gariguez, and Larido undisturbed.

Facts

Armando Dionaldo y Ebron, Renato Dionaldo y Ebron, Mariano Gariguez, Jr. y Ramos, and Rodolfo Larido y Ebron were charged with, and ultimately convicted of, the special complex crime of Kidnapping for Ransom with Homicide arising from the kidnapping and killing of Edwin Navarro.
The RTC convicted all four accused; the Court of Appeals, in a Decision dated 15 February 2013 (CA-G.R. CR-H.C. No. 02888), affirmed.
23 July 2014: The Supreme Court rendered its Resolution, affirming with modification: "all the accused-appellants herein are equally found GUILTY of the special complex crime of Kidnapping for Ransom with Homicide, and are sentenced to each suffer the penalty of reclusion perpetua, without eligibility for parole, and to pay, jointly and severally, the family of the kidnap victim Edwin Navarro the following amounts: (1) ₱100,000.00 as civil indemnity; (2) ₱100,000.00 as moral damages; and (3) ₱100,000.00 as exemplary damages," all with 6% annual interest from finality.
The accused-appellants collectively filed a motion for reconsideration, which the Court denied with finality in a Resolution dated 24 September 2014.
On that same date (24 September 2014), the Court received a letter from the Bureau of Corrections, dated 16 September 2014, informing it of the death of co-accused Renato Dionaldo on 10 June 2014 — as evidenced by his attached Certificate of Death. Renato's death thus preceded the promulgation of the Court's 23 July 2014 Resolution affirming the group's conviction.
9 September 2015: The Supreme Court (Perlas-Bernabe, J., First Division) rendered the Resolution under digest, addressing the effect of Renato's (previously undisclosed) death on the case as it pertained to him.

Arguments of the Parties

No adversarial briefing on the death issue is reflected; the matter arose from the Bureau of Corrections' notice, received on the very day the Court denied the group's motion for reconsideration with finality.

Issue

A. Main Issue (Topic/Subtopic-Centered).

Where one of several co-accused convicted in a single judgment dies before that judgment's promulgation (a fact undisclosed to the Court until after both the original Resolution and the denial of reconsideration), what is the legal effect of his death on his own criminal and civil liability, and does it affect the liabilities of his surviving co-accused?

B. Secondary Issues.

None distinct from the Main Issue; the surviving co-accused's convictions were not separately re-litigated in this Resolution.

Ruling

MAIN ISSUE — Renato's criminal and civil liability extinguished; his co-accused's liabilities unaffected. The Court held: "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." Citing People v. Amistoso, the Court reiterated: "the death of the accused pending appeal of his conviction extinguishes his criminal liability, as well as his civil liability ex delicto." Applying this: "Consequently, Renato's death on [J]une 10, 2014 renders the Court's July 23, 2014 Resolution irrelevant and ineffectual as to him, and is therefore set aside. Accordingly, the criminal case against Renato is dismissed." No mention is made of any effect on the other three co-accused, whose convictions and solidary civil liability (as adjudged in the 23 July 2014 Resolution) remain undisturbed and in force.

Dispositive portion (verbatim):

WHEREFORE, the Resolutions dated July 23, 2014 and September 24, 2014 of the Court are hereby SET ASIDE and Criminal Case No. C-68329 before the Regional Trial Court of Caloocan City, Branch 129 is DISMISSED insofar as accused-appellant RENATO DIONALDO y EBRON is concerned, in view of his demise.

SO ORDERED.

Ratio

Step 1 — The Court applied Art. 89(1), RPC to establish that Renato's death, having occurred before the promulgation of the Resolution affirming his conviction, totally extinguished his criminal liability.
Step 2 — The Court applied People v. Amistoso for the corollary principle that such extinguishment necessarily carries with it the extinguishment of the ex delicto civil liability, since the latter is wholly derivative of the former.
Step 3 — The Court limited the scope of its "set aside" disposition explicitly and exclusively to Renato, using the qualifying phrase "as to him" and "insofar as accused-appellant RENATO DIONALDO... is concerned" — a careful, deliberate textual limitation ensuring the ruling would not be misread as disturbing the final convictions of his three co-accused.
Step 4 — The Court thereby treated the criminal liability (and its correlative civil liability) of each co-accused as legally severable, notwithstanding that all four had been convicted, sentenced, and held jointly and severally liable for civil indemnity in the very same original Resolution.

Doctrine

B. Doctrines/Rules/Principles.

1. In a multi-accused conviction, the death of one co-accused, occurring before finality as to him, extinguishes only his own criminal liability and ex delicto civil liability under Art. 89(1), RPC — it does not affect the criminal or civil liability of his co-accused, whose convictions and (solidary) civil liability remain independently valid and enforceable.
2. The Court may set aside its own final Resolution selectively, as to one co-accused alone, upon proof that his death preceded the Resolution's promulgation — even where a subsequent motion for reconsideration had, in the meantime, been denied with finality as to the group collectively.

C. Distinctions/Limitations/Qualifications.

This Resolution does not disturb the solidary nature of the civil indemnity originally imposed jointly and severally on all four accused; it simply removes Renato from the group of persons against whom that solidary obligation (and the underlying criminal conviction) may be enforced, leaving the surviving co-accused's obligations (as among themselves and toward the offended party) otherwise unaffected in amount.

D. Topic/Subtopic Integration (Mandatory).

Classification: DIRECT. The Resolution squarely applies the "Effect of Death on Civil Actions" doctrine, with the added, doctrinally useful clarification of how that doctrine operates in a multi-accused case.

Separate Opinions

None. Sereno, C.J. (Chairperson), Leonardo-De Castro, Bersamin, and Perez, JJ., concurred per the signature block.

Cited Laws & Provisions

Every statute, rule, and issuance the decision turns on — the text as written, and the work it does in this case.

Special Law

Article 89, Revised Penal Code

How criminal liability is totally extinguished

Revised Penal Code (Act No. 3815)

Criminal liability is totally extinguished:

1. By the death of the convict, as to the personal penalties; and as to pecuniary penalties, liability therefor is extinguished only when the death of the offender occurs before final judgment.

2. By service of the sentence.

3. By amnesty, which completely extinguishes the penalty and all its effects.

4. By absolute pardon.

5. By prescription of the crime.

6. By prescription of the penalty.

7. By the marriage of the offended woman, as provided in article 344 of this Code.

Why it is cited here

The timing question at its sharpest: death before promulgation of the affirming resolution.

"Criminal liability is totally extinguished: 1. By the death of the convict … and as to pecuniary penalties, liability therefor is extinguished only when the death of the offender occurs before final judgment."

Renato died before the promulgation of the Resolution affirming his conviction. So although the Court had decided, the judgment had not yet been promulgated — and an unpromulgated judgment is not final.

The lesson is that "final judgment" is measured by promulgation and the lapse of the period to move for reconsideration, not by when the Court reached its conclusion. Death in that interval extinguishes everything.

Implementing Rules

Section 4, Rule 111, Rules of Court

Effect of death on civil actions

Revised Rules of Criminal Procedure (A.M. No. 00-5-03-SC, effective 1 December 2000) — Rule 111 (Prosecution of Civil Action)

The death of the accused after arraignment and during the pendency of the criminal action shall extinguish the civil liability arising from the delict. However, the independent civil action instituted under section 3 of this Rule or which thereafter is instituted to enforce liability arising from other sources of obligation may be continued against the estate or legal representative of the accused after proper substitution or against said estate, as the case may be. The heirs of the accused may be substituted for the deceased without requiring the appointment of an executor or administrator and the court may appoint a guardian ad litem for the minor heirs.

The court shall forthwith order said legal representative or representatives to appear and be substituted within a period of thirty (30) days from notice.

A final judgment entered in favor of the offended party shall be enforced in the manner especially provided in these rules for prosecuting claims against the estate of the deceased.

If the accused dies before arraignment, the case shall be dismissed without prejudice to any civil action the offended party may file against the estate of the deceased. (n)

LawPhil posts the text as amended effective 1 December 2000. Later amendments — notably to the bail and preliminary-investigation rules — are not reflected here, so check the date of the decision against the date of the amendment.

Why it is cited here

The civil consequence, and the survival clause.

"The death of the accused after arraignment and during the pendency of the criminal action shall extinguish the civil liability arising from the delict. However, the independent civil action … or which thereafter is instituted to enforce liability arising from other sources of obligation may be continued against the estate or legal representative."

A case pending promulgation is still pending, so the section applies squarely.

Note the practical asymmetry it creates among co-accused: where several are convicted and one dies, the case is terminated as to him alone. The others' convictions and civil liabilities stand.

Special Law

Article 100, Revised Penal Code

Civil liability of person guilty of felony

Revised Penal Code (Act No. 3815)

Every person criminally liable for a felony is also civilly liable.

Why it is cited here

The dependency that makes the extinguishment total.

"Every person criminally liable for a felony is also civilly liable."

Civil liability ex delicto is derived from the criminal liability. It has no independent source, so it cannot outlive what it derives from.

That is the whole of the Bayotas rule in one line — and it is also why the exception in Rule 111, Section 4 is framed as it is. The question is never whether the offended party was harmed but which obligation the claim rests on: Article 100, which dies with the crime, or something else, which does not.

Related notes:

People v. Jao — companion case with an identical "one of two/multiple co-accused dies" pattern.
People v. Abungan — source of the "dismiss the case, not merely the appeal" disposition rule, here applied selectively to only one co-accused.
Rule 111, Revised Rules of Criminal Procedure — Sec. 4, effect of death on civil actions.
People v. Bayotas — foundational doctrine on the effect of the accused's death on criminal and civil liability.

Source: https://elibrary.judiciary.gov.ph (People v. Dionaldo, G.R. No. 207949, September 9, 2015)

Cited laws & provisions

Article 89, Revised Penal Code

Special Law

How criminal liability is totally extinguished

Revised Penal Code (Act No. 3815)

Criminal liability is totally extinguished:

1. By the death of the convict, as to the personal penalties; and as to pecuniary penalties, liability therefor is extinguished only when the death of the offender occurs before final judgment.

2. By service of the sentence.

3. By amnesty, which completely extinguishes the penalty and all its effects.

4. By absolute pardon.

5. By prescription of the crime.

6. By prescription of the penalty.

7. By the marriage of the offended woman, as provided in article 344 of this Code.

Why it is cited here

The timing question at its sharpest: death before promulgation of the affirming resolution.

Full entry below ↓

Section 4, Rule 111, Rules of Court

Implementing Rules

Effect of death on civil actions

Revised Rules of Criminal Procedure (A.M. No. 00-5-03-SC, effective 1 December 2000) — Rule 111 (Prosecution of Civil Action)

The court shall forthwith order said legal representative or representatives to appear and be substituted within a period of thirty (30) days from notice.

A final judgment entered in favor of the offended party shall be enforced in the manner especially provided in these rules for prosecuting claims against the estate of the deceased.

If the accused dies before arraignment, the case shall be dismissed without prejudice to any civil action the offended party may file against the estate of the deceased. (n)

Why it is cited here

The civil consequence, and the survival clause.

A case pending promulgation is still pending, so the section applies squarely.

Note the practical asymmetry it creates among co-accused: where several are convicted and one dies, the case is terminated as to him alone. The others' convictions and civil liabilities stand.

Full entry below ↓

Article 100, Revised Penal Code

Special Law

Civil liability of person guilty of felony

Revised Penal Code (Act No. 3815)

Every person criminally liable for a felony is also civilly liable.

Why it is cited here

The dependency that makes the extinguishment total.

"Every person criminally liable for a felony is also civilly liable."

Civil liability ex delicto is derived from the criminal liability. It has no independent source, so it cannot outlive what it derives from.

Full entry below ↓

ℹ️ Assigned Topic/Subtopic

IV. Effect of Death on Civil Actions

ℹ️ Distinct nuance: death of only one among several co-accused

Facts

Armando Dionaldo y Ebron, Renato Dionaldo y Ebron, Mariano Gariguez, Jr. y Ramos and Rodolfo Larido y Ebron were charged with and convicted of the special complex crime of Kidnapping for Ransom with Homicide arising from the kidnapping and killing of Edwin Navarro.
The RTC convicted all four, and on 15 February 2013 the Court of Appeals affirmed (CA-G.R. CR-H.C. No. 02888).
On 23 July 2014 the Supreme Court affirmed with modification: "all the accused-appellants herein are equally found GUILTY… and are sentenced to each suffer the penalty of reclusion perpetua, without eligibility for parole, and to pay, jointly and severally, the family of the kidnap victim Edwin Navarro… ₱100,000.00 as civil indemnity; ₱100,000.00 as moral damages; and ₱100,000.00 as exemplary damages," with 6% interest from finality.
Their joint motion for reconsideration was denied with finality on 24 September 2014.
On that very date the Court received a letter dated 16 September 2014 from the Bureau of Corrections reporting that Renato Dionaldo had died on 10 June 2014, with his Certificate of Death attached — a month and a half before the 23 July 2014 Resolution. One of four; the other three were alive throughout.
On 9 September 2015 the First Division, through Justice Perlas-Bernabe, set aside both Resolutions and dismissed the case as to Renato alone.

Issue

Ruling

WHEREFORE, the Resolutions dated July 23, 2014 and September 24, 2014 of the Court are hereby SET ASIDE and Criminal Case No. C-68329 before the Regional Trial Court of Caloocan City, Branch 129 is DISMISSED insofar as accused-appellant RENATO DIONALDO y EBRON is concerned, in view of his demise.

SO ORDERED.

Ratio

Article 89(1) applied to Renato alone: his death having preceded the Resolution affirming his conviction, his criminal liability was totally extinguished.
People v. Amistoso supplied the corollary — that extinguishment necessarily carries with it the ex delicto civil liability, the latter being wholly derivative of the former.
The Court limited its disposition textually and deliberately — "as to him" and "insofar as accused-appellant RENATO DIONALDO… is concerned" — ensuring the ruling could not be misread as disturbing the final convictions of the other three.
So the liabilities were treated as legally severable, even though all four had been convicted, sentenced, and held jointly and severally liable in the same Resolution.

Doctrine

Extinguishment by death operates individually, not collectively.

Where one of several co-accused dies before promulgation of the judgment affirming their conviction, his criminal and ex delicto civil liability are extinguished and his case dismissed, while the convictions and civil liability of the surviving co-accused remain fully in force.
Civil liability from non-delictual sources survives as to the deceased and may be pursued by separate action against his estate.

Limits.

Solidarity does not travel with the dismissal. The other three remain jointly and severally liable for the full award — the death removes one obligor from the criminal judgment, it does not reduce the amount recoverable from those who remain.
And the disposition's wording is doing real work: without the "as to him" limitation, setting aside two Resolutions that had affirmed all four convictions could have been read as unsettling the whole judgment.
That drafting care is the practical lesson. Read with People v. Culas and People v. Antido for the single-accused pattern, and note that this case adds the only variable the others lack — plurality of accused. The rule itself is unchanged; only its addressee is narrowed.

Full Digest — Recitation Format

Gist

Classification: DIRECT. This Resolution applies the Bayotas framework's extinguishment rule in the distinct context of a multi-accused conviction, clarifying that death's legal effect is individualized rather than collective — squarely within this Topic.
Armando Dionaldo, Renato Dionaldo, Mariano Gariguez, Jr., and Rodolfo Larido were convicted of the special complex crime of Kidnapping for Ransom with Homicide in connection with the death of kidnap victim Edwin Navarro. On 23 July 2014, the Supreme Court rendered a Resolution affirming their conviction with modification, sentencing each to reclusion perpetua without eligibility for parole and ordering them, jointly and severally, to pay the victim's family ₱100,000 each as civil indemnity, moral damages, and exemplary damages.
The accused collectively moved for reconsideration, which the Court denied with finality in a Resolution dated 24 September 2014. On that same date, the Court received a letter from the Bureau of Corrections, dated 16 September 2014, informing it that co-accused Renato Dionaldo had died on 10 June 2014 — a date before the Court's own 23 July 2014 Resolution affirming the group's conviction.
Applying Art. 89(1), RPC, and People v. Amistoso, the Supreme Court held that Renato's death, having preceded the promulgation of the 23 July 2014 Resolution, totally extinguished his criminal liability as well as his civil liability ex delicto, rendering that Resolution (and the subsequent 24 September 2014 denial of reconsideration) "irrelevant and ineffectual as to him." The Court set aside its prior Resolutions and dismissed the criminal case insofar as Renato Dionaldo alone was concerned — leaving the convictions of Armando Dionaldo, Gariguez, and Larido undisturbed.

Facts

Armando Dionaldo y Ebron, Renato Dionaldo y Ebron, Mariano Gariguez, Jr. y Ramos, and Rodolfo Larido y Ebron were charged with, and ultimately convicted of, the special complex crime of Kidnapping for Ransom with Homicide arising from the kidnapping and killing of Edwin Navarro.
The RTC convicted all four accused; the Court of Appeals, in a Decision dated 15 February 2013 (CA-G.R. CR-H.C. No. 02888), affirmed.
23 July 2014: The Supreme Court rendered its Resolution, affirming with modification: "all the accused-appellants herein are equally found GUILTY of the special complex crime of Kidnapping for Ransom with Homicide, and are sentenced to each suffer the penalty of reclusion perpetua, without eligibility for parole, and to pay, jointly and severally, the family of the kidnap victim Edwin Navarro the following amounts: (1) ₱100,000.00 as civil indemnity; (2) ₱100,000.00 as moral damages; and (3) ₱100,000.00 as exemplary damages," all with 6% annual interest from finality.
The accused-appellants collectively filed a motion for reconsideration, which the Court denied with finality in a Resolution dated 24 September 2014.
On that same date (24 September 2014), the Court received a letter from the Bureau of Corrections, dated 16 September 2014, informing it of the death of co-accused Renato Dionaldo on 10 June 2014 — as evidenced by his attached Certificate of Death. Renato's death thus preceded the promulgation of the Court's 23 July 2014 Resolution affirming the group's conviction.
9 September 2015: The Supreme Court (Perlas-Bernabe, J., First Division) rendered the Resolution under digest, addressing the effect of Renato's (previously undisclosed) death on the case as it pertained to him.

Arguments of the Parties

No adversarial briefing on the death issue is reflected; the matter arose from the Bureau of Corrections' notice, received on the very day the Court denied the group's motion for reconsideration with finality.

Issue

A. Main Issue (Topic/Subtopic-Centered).

Where one of several co-accused convicted in a single judgment dies before that judgment's promulgation (a fact undisclosed to the Court until after both the original Resolution and the denial of reconsideration), what is the legal effect of his death on his own criminal and civil liability, and does it affect the liabilities of his surviving co-accused?

B. Secondary Issues.

None distinct from the Main Issue; the surviving co-accused's convictions were not separately re-litigated in this Resolution.

Ruling

MAIN ISSUE — Renato's criminal and civil liability extinguished; his co-accused's liabilities unaffected. The Court held: "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." Citing People v. Amistoso, the Court reiterated: "the death of the accused pending appeal of his conviction extinguishes his criminal liability, as well as his civil liability ex delicto." Applying this: "Consequently, Renato's death on [J]une 10, 2014 renders the Court's July 23, 2014 Resolution irrelevant and ineffectual as to him, and is therefore set aside. Accordingly, the criminal case against Renato is dismissed." No mention is made of any effect on the other three co-accused, whose convictions and solidary civil liability (as adjudged in the 23 July 2014 Resolution) remain undisturbed and in force.

Dispositive portion (verbatim):

WHEREFORE, the Resolutions dated July 23, 2014 and September 24, 2014 of the Court are hereby SET ASIDE and Criminal Case No. C-68329 before the Regional Trial Court of Caloocan City, Branch 129 is DISMISSED insofar as accused-appellant RENATO DIONALDO y EBRON is concerned, in view of his demise.

SO ORDERED.

Ratio

Step 1 — The Court applied Art. 89(1), RPC to establish that Renato's death, having occurred before the promulgation of the Resolution affirming his conviction, totally extinguished his criminal liability.
Step 2 — The Court applied People v. Amistoso for the corollary principle that such extinguishment necessarily carries with it the extinguishment of the ex delicto civil liability, since the latter is wholly derivative of the former.
Step 3 — The Court limited the scope of its "set aside" disposition explicitly and exclusively to Renato, using the qualifying phrase "as to him" and "insofar as accused-appellant RENATO DIONALDO... is concerned" — a careful, deliberate textual limitation ensuring the ruling would not be misread as disturbing the final convictions of his three co-accused.
Step 4 — The Court thereby treated the criminal liability (and its correlative civil liability) of each co-accused as legally severable, notwithstanding that all four had been convicted, sentenced, and held jointly and severally liable for civil indemnity in the very same original Resolution.

Doctrine

B. Doctrines/Rules/Principles.

1. In a multi-accused conviction, the death of one co-accused, occurring before finality as to him, extinguishes only his own criminal liability and ex delicto civil liability under Art. 89(1), RPC — it does not affect the criminal or civil liability of his co-accused, whose convictions and (solidary) civil liability remain independently valid and enforceable.
2. The Court may set aside its own final Resolution selectively, as to one co-accused alone, upon proof that his death preceded the Resolution's promulgation — even where a subsequent motion for reconsideration had, in the meantime, been denied with finality as to the group collectively.

C. Distinctions/Limitations/Qualifications.

This Resolution does not disturb the solidary nature of the civil indemnity originally imposed jointly and severally on all four accused; it simply removes Renato from the group of persons against whom that solidary obligation (and the underlying criminal conviction) may be enforced, leaving the surviving co-accused's obligations (as among themselves and toward the offended party) otherwise unaffected in amount.

D. Topic/Subtopic Integration (Mandatory).

Classification: DIRECT. The Resolution squarely applies the "Effect of Death on Civil Actions" doctrine, with the added, doctrinally useful clarification of how that doctrine operates in a multi-accused case.

Separate Opinions

None. Sereno, C.J. (Chairperson), Leonardo-De Castro, Bersamin, and Perez, JJ., concurred per the signature block.