Case Digest (G.R. No. 102007)
Facts:
In Criminal Case No. C-3217 before Branch 16 of the Regional Trial Court in Roxas City, Rogelio Bayotas y Cordova was charged with rape and, on June 19, 1991, convicted by Judge Manuel E. Autajay. While his appeal was pending before the Supreme Court, Bayotas died on February 4, 1992, at the National Bilibid Hospital due to cardio-respiratory arrest secondary to hepatic encephalopathy secondary to hepatocarcinoma. On May 20, 1992, the Supreme Court dismissed the criminal aspect of his appeal but called for the Solicitor General’s comment on Bayotas’s civil liability arising from the same offense. The Solicitor General argued that civil liability survives the death of the offender, relying on People v. Sendaydiego, whereas counsel for the accused maintained that, under People v. Castillo, the death of an accused before final judgment extinguishes both criminal and civil obligations. The case thus reached the Supreme Court en banc to resolve whether Bayotas’s demise pending appeal...