G.R. No. 175784 - People vs. Ayochok y Tauli

On or about July 15, 2001, Jaime Ayochok y Tauli was charged with the crime of Murder for the killing of Senior Police Officer 1 (SPO1) Claudio Caligtan in Baguio City.
The amended information by Prosecutor Benedicto T. Carantes charged Ayochok with murder under Article 248 of the Revised Penal Code, emphasizing premeditation, treachery, and cruelty.
Specific circumstances included that the victim was caught off guard while relieving himself, with Ayochok shooting him several times, causing hypovolemic shock and multiple fatal gunshot wounds.

At trial in Criminal Case No. 18658-R before the Regional Trial Court (RTC) of Baguio City, Branch 6, Ayochok pleaded not guilty.
After trial on the merits, the RTC rendered a decision on August 13, 2003, finding Ayochok guilty beyond reasonable doubt of murder.
The RTC sentenced him to reclusion perpetua and ordered him to pay various indemnities and damages to the victim’s heirs, which included civil indemnity, moral damages, actual damages, and unearned income.
Credit for preventive imprisonment under Article 29 of the Revised Penal Code was applied to Ayochok’s sentence.

The case was elevated for automatic review and was initially docketed as G.R. No. 161469; however, following People v. Mateo, it was transferred to the Court of Appeals as CA-G.R. CR No. 00949.
On June 28, 2005, the Court of Appeals affirmed with modifications the RTC decision, particularly reducing the amounts for civil indemnity, moral damages, actual damages, and unearned income.
Ayochok initially filed a Motion for Reconsideration and later moved to withdraw the motion, seeking direct appeal to the Supreme Court; however, the appellate court denied his motion to withdraw and his subsequent motion for reconsideration.

On January 15, 2010, while his appeal was still pending, Ayochok died at the Philippine General Hospital in Manila.
The death was verified by a certified true copy of his death certificate provided by the New Bilibid Prison.
Under Article 89(1) of the Revised Penal Code and the guidelines established in People v. Bayotas, the accused’s death extinguished both his criminal liability and his civil liability arising solely from the offense, given that no final judgment of conviction was rendered prior to his death.
The issue of separate civil liability in cases where there might be an alternative source of obligation was noted, but as applied to this case, both the criminal and the civil (ex delicto) liabilities were extinguished by his death.

Whether the death of the accused-appellant, while his appeal was still pending, extinguishes his criminal liability for the crime of murder.
Whether the civil liability based solely on the crime (civil liability ex delicto) is also extinguished by the accused’s death prior to final judgment.
How the principles contained in Article 89 of the Revised Penal Code and precedents such as People v. Bayotas affect the pending appeal and the enforceability of any civil indemnity awards.