G.R. No. L-24940 - People vs. Saclao

The People of the Philippines initiated a criminal prosecution against Jose Saclao alias Pepe for the crime of murder.
The murder involved the killing of Donato Ignacio, an event occurring in Nampicuan, Nueva Ecija.
The trial was conducted in Criminal Case 99-G of the Court of First Instance of Guimba, Nueva Ecija.

Jose Saclao was found guilty of murder on June 8, 1965.
The Court sentenced him to reclusion perpetua (life imprisonment) and imposed additional accessories provided by law.
The sentence included an order to indemnify the heirs of Donato Ignacio in the sum of P6,000 and to pay the costs of the proceedings.
An appeal was duly and seasonably taken to the Supreme Court, and the case was docketed as G.R. No. L-24940.

On December 16, 1969, the Solicitor General filed a manifestation in the appeal.
The manifestation asserted that official information from the Philippine Constabulary confirmed that Jose Saclao was a detention prisoner at the PC Stockade in Camp Crame, Quezon City, from July 29, 1969, until his escape and subsequent death on September 8, 1969.
Multiple annexes accompanied the manifestation, which included:

Annex A – A certification by Colonel N.C. Camello reconfirming Saclao’s detention, escape, and death, and identifying him as the accused in Criminal Case 99-G.
Annex A-1 – A compilation of personal data on the accused as maintained by the Philippine Constabulary.
Annex A-2 – A detailed statement of events immediately preceding and following his demise.
Annex A-3 – The certificate of death of Jose Saclao, listing his address in Nampicuan, Nueva Ecija.
Annex A-4 – The certificate of post-mortem examination conducted by the medico-legal division of the National Bureau of Investigation.

Annex B & B-1 – Communications from the Chief of the Interpol Division, National Bureau of Investigation, and a certification by Lt. Col. C. Perez of the Philippine Constabulary, establishing that Saclao, who had escaped from detention, was indeed responsible for the murder and was later slain on September 8, 1969.
Annex C – A letter from Director Alejo Santos of the Bureau of Prisons confirming Saclao's conviction in Criminal Case 99-G, his sentence, and his subsequent escape from the New Bilibid Prisons.

The presented evidence unequivocally established that Jose Saclao alias Pepe, the defendant-appellant, had died.
With the proof of his death consolidated by various official records and certifications, the factual basis of his appeal was fundamentally undermined.

Does the confirmed death of the defendant-appellant, Jose Saclao, render the pending criminal appeal moot and necessitate the dismissal of the case?
Is the evidence presented, including multiple annexed certifications and official communications, sufficient to conclusively establish the identity and demise of Jose Saclao?
Should criminal proceedings be sustained against a defendant who is no longer living, thereby affecting the validity of the conviction and subsequent appeal?