People of the Philippines v Bayotas, G.R. No. 102007, September 2, 1994 CASE DIGEST

 Facts:

    The respondent Rogelio Bayotas was charged with rape and eventually convicted thereof on June 19, 1994. Pending the appeal of his conviction, Bayotas died on February 4, 1992. Consequently, the Supreme Court dismissed the criminal aspect of the appeal. However, it required the Solicitor General to file its comment with regard to the civil liability arising from the offense charged. The OSG expressed his view that the death of Bayotas did not extinguish his civil liability. The counsel of Bayotas opposed the view of the OSG arguing that the death of Bayotas while judgement of conviction was pending appeal extinguishes both criminal and civil penalties.

Issue:

    WoN Bayotas' civil liability is extinguished by his death?

Ruling:

(Article 1162; 2176; 2180; RPC Art. 103)

    Yes, Bayotas's death extinguished his civil liability.

    Death of the accused pending appeal of his conviction extinguishes his criminal liability as well as the civil liability based solely thereon.

    The death of the accused prior to final judgement terminates his civil liability and only the civil liability arising from and based solely on the offence committed, i.e. civil liability ex delicto in seso strictiore.

    Corollarily, the claim for civil liability survives notwithstanding the death of the accused, if the same may also be predicated on a source of obligation other than delict.