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    People v. Bayotas

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    Kimmy
    1) Rogelio Bayotas was convicted of rape by the Regional Trial Court but died pending appeal of his conviction. 2) The Solicitor General argued that Bayotas' death did not extinguish his civil liability from the offense, but counsel for Bayotas argued that both his criminal and civil liability were extinguished upon his death. 3) The Supreme Court held that Bayotas' death while his conviction was on appeal extinguished both his criminal liability and civil liability based on the criminal conviction. However, any civil liability from other potential sources could still be pursued through a separate civil action.

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    People v. Bayotas

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    Kimmy
    78 views1 page
    1) Rogelio Bayotas was convicted of rape by the Regional Trial Court but died pending appeal of his conviction. 2) The Solicitor General argued that Bayotas' death did not extinguish his civil liability from the offense, but counsel for Bayotas argued that both his criminal and civil liability were extinguished upon his death. 3) The Supreme Court held that Bayotas' death while his conviction was on appeal extinguished both his criminal liability and civil liability based on the criminal conviction. However, any civil liability from other potential sources could still be pursued through a separate civil action.

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    Crim Law Digest

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    1) Rogelio Bayotas was convicted of rape by the Regional Trial Court but died pending appeal of his conviction. 2) The Solicitor General argued that Bayotas' death did not extinguish his civil liability from the offense, but counsel for Bayotas argued that both his criminal and civil liability were extinguished upon his death. 3) The Supreme Court held that Bayotas' death while his conviction was on appeal extinguished both his criminal liability and civil liability based on the criminal conviction. However, any civil liability from other potential sources could still be pursued through a separate civil action.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    78 views1 page

    People v. Bayotas

    Uploaded by

    Kimmy
    1) Rogelio Bayotas was convicted of rape by the Regional Trial Court but died pending appeal of his conviction. 2) The Solicitor General argued that Bayotas' death did not extinguish his civil liability from the offense, but counsel for Bayotas argued that both his criminal and civil liability were extinguished upon his death. 3) The Supreme Court held that Bayotas' death while his conviction was on appeal extinguished both his criminal liability and civil liability based on the criminal conviction. However, any civil liability from other potential sources could still be pursued through a separate civil action.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    BAGGAY, Delonix Kim Perkins D.

    Criminal Law 1
    2019-80114 1st year – Block 5

    PEOPLE v. BAYOTAS
    G.R. No. 102007
    2 September 1994

    ROMERO, J:
    Facts:
    Rogelio Bayotas y Cordova was convicted with Rape by the Regional Trial Court of
    Roxas City. During the pendency of his appeal, Bayotas died at the National Bilibid Hospital.
    Consequently, the Supreme Court dismissed the criminal aspect of the appeal. However, it
    required the Solicitor General to file its comment with regard to Bayotas’ civil liability arising
    from the offense charged.

    In his comment, the Solicitor General expressed his view that the death of accused-
    appellant did not extinguish his civil liability as a result of his commission of the offense
    charged. The Solicitor General, relying on the case of People v. Sendaydiego insists that the
    appeal should still be resolved for the purpose of reviewing his conviction by the lower court on
    which the civil liability is based.

    Counsel for the accused-appellant, on the other hand, opposed the view of the Solicitor
    General arguing that the death of the accused while judgment of conviction is pending appeal
    extinguishes both his criminal and civil penalties. In support of his position, said counsel invoked
    the ruling of the Court of Appeals in People v. Castillo and Ocfemia which held that the civil
    obligation in a criminal case takes root in the criminal liability and, therefore, civil liability is
    extinguished if accused should die before final judgment is rendered.

    Issue:
    Whether or not the death of the accused while judgment of conviction is pending appeal
    extinguishes both his criminal and civil penalties.
    Held:
    YES. Death of the accused while judgment of conviction is pending appeal extinguishes
    his criminal liability as well as civil liability based thereon. Consequently, the claim for civil
    liability survives notwithstanding the death of the accused, if the same may also be predicted on
    sources of obligation from which the civil liability may arise as a result of the same act or
    omission (e.g. law, contracts, quasi-contracts, quasi-delicts, etc.)
    Where the civil liability survives, an action for recovery therefore may be pursued but
    only by way of filing a separate civil action and subject to Section 1, Rule 111 of the 1985 Rules
    on Criminal Procedure as amended.

    64

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