People v. Albofera

Summary

This Supreme Court resolution addressed the legal effects of presidential pardon on criminal and civil liability. Accused-appellants convicted of Murder sought case dismissal based on absolute pardon granted by the President on January 29, 1987. The Court held that since the pardon was granted before the 1987 Constitution's effectivity, it was valid without requiring final conviction first. While the pardon extinguished criminal liability and eliminated the reclusion perpetua penalty, civil liability remained intact pursuant to Article 36 of the Revised Penal Code. The case establishes the principle that pardon absolves criminal liability but not civil indemnity obligations to victims' heirs, demonstrating the distinction between criminal punishment and civil compensation in Philippine jurisprudence.