People v. Tirol (Civil Damages)

Facts: Kosain Manibpol and his family were sleeping when he heard the dog bark. When we went to investigate, 2 persons have already come up to their house, asking if they can borrow his land. After he gave his consent, Kulas arrived, flashed the light in his face and boxed him. When he fell, the assailant’s companions (more than 10 armed men) came in hacked him and his wife and 7 children. His wife died, 6 kids. Of the 14 suspects, only 2 were apprehended, Ciriaco Baldesco and Bonifacio Tirol. After they were found guilty of the crime of murder of 7 persons, they filed an appeal, during which Baldesco died.

Issue: Whether or not Baldesco will be liable for civil damages

Held: The courts dismissed the case insofar as the criminal liability of Baldesco is concerned. However following the doctrine in People vs. Sendaydiego, the appeal will be resolved only for the purpose of determining his criminal liability which is the basis of the civil liability for which his estate is liable. Art 42 states that criminal liability is extinguished in death. The effect of death upon rights and obligations of the deceased is determined by law, by contract and by will. Civil liability is not extngsh’d.