People of the Philippines v. Rogelio Bayotas y Cordova (Extinguishment of Civil Liability upon Death of Accused)
Facts:
In Criminal Case No. C-3217 before Branch 16 of the RTC Roxas City, Rogelio Bayotas y Cordova was charged with rape. He was convicted on June 19, 1991, in a decision penned by Judge Manuel E. Autajay. Bayotas appealed his conviction, but he died on February 4, 1992, at the National Bilibid Hospital due to cardiorespiratory arrest secondary to hepatic encephalopathy secondary to hepato carcinoma gastric malingering. Following his death, the Supreme Court, in a Resolution dated May 20, 1992, dismissed the criminal aspect of the appeal but required the Solicitor General to comment on Bayotas’ civil liability arising from the offense. The Solicitor General held that Bayotas’ death did not extinguish his civil liability and emphasized the need to resolve the appeal to affirm the basis for the civil liability. Counsel for Bayotas countered that the accused’s death while the conviction was pending appeal abates both the criminal and the pecuniary penalties.
Issues:
The pivotal legal issue before the Supreme Court was whether the death of the accused pending appeal of his conviction extinguishes not only his criminal liability but also his civil liability arising from the offense charged.
Court’s Decision:
The Supreme Court held that Bayotas’ death pending appeal of his conviction extinguished both his criminal liability and the civil liability based solely on the criminal act, i.e., rape. The Supreme Court dismissed the appeal without qualifications, aligning with the legal principle that death terminates criminal liability as well as civil liability that is solely based on the criminal act (civil liability ex delicto).
Doctrine:
The Court reiterated the doctrine that death of the accused while their conviction is on appeal extinguishes not only the criminal liability but also the civil liability that is anchored solely on the criminal act (civil liability ex delicto). Furthermore, civil liability may still be pursued if it arises from sources other than the criminal offense itself, such as law, contracts, quasi-contracts, or quasi-delicts.
Class Notes:
1. Criminal liability is extinguished upon the death of the convict (RPC, Art. 89).
2. Civil liability ex delicto (civil liability arising solely from a criminal offense), is extinguished upon the death of the accused before final judgment (ibid).
3. Separate civil actions based on sources other than the offense (e.g., contracts or quasi-delicts) may be pursued against the estate or legal representatives of the deceased (Civil Code, Arts. 1157 and 1311).
4. Separate civil actions not based on the criminal act (i.e., independent from the criminal offense) must follow proper procedures under civil law, and the death of the accused does not bar their pursuit (Civil Code, Arts. 33, 1157).
Historical Background:
Historically, the linkage between criminal liability and the civil liability arising therefrom had been subject to various interpretations within Philippine jurisprudence. Earlier cases such as People v. Castillo and subsequent ones like People v. Sendaydiego evolved the application of the law concerning the survival of civil liability post-mortem of the accused. The Supreme Court, in this case, revisited and clarified the doctrine, drawing a clear line demarcating when civil liability continues beyond the death of the accused (when based on sources other than the criminal act) and when it does not (when solely based on the criminal act for which the accused was charged). This decision reflects the Court’s commitment to jurisprudential consistency while ensuring that the rights of the offended parties in civil actions are maintained through alternative legal remedies under the Civil Code.
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