XXX v. People

Summary

This Supreme Court case involves the extinguishment of criminal liability due to the death of accused XXX during appeal proceedings. Originally charged with three violations of RA 9262 (Anti-Violence Against Women and Their Children Act), petitioner was convicted by the Court of Appeals and the Supreme Court initially modified the decision in July 2020, acquitting him in one case while imposing penalties in two others. However, when counsel informed the Court that petitioner had died on October 12, 2019, the Supreme Court applied Article 89 of the Revised Penal Code, which provides that criminal liability is totally extinguished by the death of the accused before final judgment. The Court set aside its previous resolution and dismissed all three criminal cases (Nos. 06-2173, 06-2174, and 06-2175), declaring the case closed and terminated. The decision clarifies that while criminal liability is extinguished by death, civil liability may survive if based on sources other than delict, and can be pursued through separate civil action against the estate.