A.M. No. RTJ-17-2506 - Office of the Court Administrator vs. Reyes

The case originated from the decision of the Court of Appeals (CA) dated December 7, 2012 in CA-G.R. CR-H.C. No. 04602.
The CA found accused-appellant Romeo Antido y Lantayan a.k.a. Romeo Antigo y Lantayan alias "Jon-Jon" guilty beyond reasonable doubt of the crime of rape under RA 8353.
On April 7, 2014, the Supreme Court, through a Resolution penned by Associate Justice Manuel M. Barrios and concurring justices, affirmed the CA’s decision.
The affirmed decision included sentencing the accused to reclusion perpetua and imposing various monetary penalties on him:

Despite the procedural progression, it was established that accused-appellant had already died on December 28, 2013, as attested by his Certificate of Death.
The death occurred prior to the final promulgation of the conviction.
Owing to the death of the accused, important legal consequences arose regarding the continuance of the criminal and civil actions.

Article 89(1) of the Revised Penal Code was cited, which provides that criminal liability is totally extinguished by the death of the accused. Specifically:

The ruling relied on previous jurisprudence, notably People v. Culas, which explained that the death of an accused pending appeal extinguishes both his criminal and related civil liabilities (if based solely on the criminal offense).

The civil action for damages—initiated together with the criminal case—is deemed ipso facto extinguished when based solely on criminal liability (delict).
However, if the civil claim may also be founded on other sources of obligation (such as contract, quasi-contract, or quasi-delict), the possibility for a separate civil action against the estate of the deceased remains open.
Additionally, when a civil case is instituted together with the criminal case, the statute of limitations on the civil claim is interrupted, preventing forfeiture by prescription.

Whether the death of the accused-appellant prior to final conviction extinguishes his criminal liability.

Specifically, does Article 89(1) of the Revised Penal Code mandate the dismissal of criminal prosecution upon the defendant's death?
What is the effect of the accused's death on the collateral civil action for damages that was pursued alongside the criminal action?

Whether there remains any surviving civil liability for the private offended party.

Can the victim pursue a separate civil action against the accused’s estate if the civil liability is based on sources other than the criminal delict?
How does the interruption of the prescription period during the criminal case impact the victim’s right to seek recovery?