Case Digest (G.R. No. 102007)
Facts:
People of the Philippines v. Rogelio Bayotas y Cordova, G.R. No. 102007, September 02, 1994, Supreme Court En Banc, Romero, J., writing for the Court. In Criminal Case No. C-3217 before Branch 16, Regional Trial Court, Roxas City, Rogelio Bayotas y Cordova (accused-appellant) was charged with rape and was convicted on June 19, 1991 in a decision by Judge Manuel E. Autajay. Bayotas took an appeal which was pending before the Supreme Court.While the appeal was pending, Bayotas died on February 4, 1992 at the National Bilibid Hospital. Following his death, the Supreme Court, by Resolution dated May 20, 1992, dismissed the criminal aspect of the appeal but requested the Solicitor General to comment on whether Bayotas’ civil liability arising from the offense survived his death.
In its comment the Solicitor General argued that Bayotas’ civil liability did not extinguish upon his death and relied principally on People v. Sendaydiego to urge that the appeal be resolved insofar as civil liability was concerned. Counsel for Bayotas countered that both the criminal and civil liabilities were extinguished by death, invoking the Court of Appeals’ ruling in People v. Castillo and Ocfemia and related Supreme Court decisions that had treated civil liability ex delicto as dependent on a final criminal judgment.
Confronted with conflicting authorities, the Court reviewed prior jurisprudence (including People v. Castillo, People v. Bonifacio Alison, Belamala, Torrijos, and Sendaydiego) an...(Subscriber-Only)
Issues:
- Does the death of an accused while his conviction is pending on appeal extinguish his civil liability arising solely from the criminal offense (civil liability ex de...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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