People of the Philippines vs Jaime Jose GR no.

L-28397 71
SCRA 273 Case Digest

People of the Philippines vs Jaime Jose GR no. L-28397

71 SCRA 273
Concept:
Article 1231. Obligations are extinguished:
(1) By payment or performance;
(2) By the loss of the thing due;
(3) By the condonation or remission of the debt;
(4) By the confusion or merger of the rights of creditor
and debtor;
(5) By compensation;
(6) By novation.
Other causes of extinguishment of obligations, such as
annulment, rescission, fulfillment of a resolutory condition,
and prescription, are governed elsewhere in this Code.
Facts:
Jaime Jose and George Tillman was acquitted in the crime of robbery but found guilty beyond reasonable
doubt in the complex crime of forcible abduction with rape in a criminal case and both are sentenced in
the penalty of death but with recommendation to be commuted to life imprisonment
Jose and Tillman to pay jointly and severally the amount of P6,000 to Zenaida dela Cruz
July 4th 1966, Jose and Tillman along with John Doe and Roy, Peter and and Richard Roe, armed and
with a vehicle abducted Dela Cruz and with carnal knowledge, raped her. (the other four guys are actually
unidentified and the whereabouts are unknown, the names were just stated in the facts)
The facts has two sides the prosecutor side and the defendant side:
Prosecutor: Dela Cruz whilst riding a golden taxicab driven by Osmundo delacruz (no relation) was
forcibly taken by five men in a Mercedes benz and the same five men divested her jewelries. She was
then taken to Queens Motel where she got raped along with another woman named Araceli Sy.
Defendant side: A man named Crisologo along with his two companions went to Jaime Jose and Tillman
to borrow Joses mercedez benz but the latter refused stating that him and Tillman are going to party and
that they should tag along so that after the party they can go to the bayside. Whilst on the road they were
hailed by two women, dela cruz and Sy, and joined them inside the mercedez benz and went to the
Queens motel. The defendants stated that there was no forcible abduction.
The Judge took emphasis and credibility on dela Cruzs sworn statement.
Prosecutor has evidence while the defendants failed to present evidence and their statement is much
more improbable.
During the pendency of this case, Jose died
Issue: W/ON civil liabilities are extinguished
Held: Yes, the court ruled that accused is relieved in this case of all personal and pecuniary penalties
attendant to his crime, his death occurring before rendition of final judgment herein. (The ruling was
different in the case of Torrijos vs CA)