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    G.R. NO. 102007 SEPTEMBER 2, 1994 People of The Philippines VS. Rogelio Bayotas Facts

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    Amicus Curiae
    Rogelio Bayotas was convicted of rape but died pending appeal of his conviction. The Supreme Court had to determine whether his death extinguished his criminal and civil liability. In its ruling, the Court held that Bayotas' death extinguished both his criminal liability and civil liability based solely on the rape charge. However, civil liability could still be pursued through a separate civil action if it was predicated on something other than the criminal act, such as a contract. The private offended party also does not risk losing the ability to file a civil action due to prescription, as the statute of limitations is interrupted during the criminal case proceedings.

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    G.R. NO. 102007 SEPTEMBER 2, 1994 People of The Philippines VS. Rogelio Bayotas Facts

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    Amicus Curiae
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    Rogelio Bayotas was convicted of rape but died pending appeal of his conviction. The Supreme Court had to determine whether his death extinguished his criminal and civil liability. In its ruling, the Court held that Bayotas' death extinguished both his criminal liability and civil liability based solely on the rape charge. However, civil liability could still be pursued through a separate civil action if it was predicated on something other than the criminal act, such as a contract. The private offended party also does not risk losing the ability to file a civil action due to prescription, as the statute of limitations is interrupted during the criminal case proceedings.

    Original Title

    People vs. Bayotas, September 2, 1994

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    Rogelio Bayotas was convicted of rape but died pending appeal of his conviction. The Supreme Court had to determine whether his death extinguished his criminal and civil liability. In its ruling, the Court held that Bayotas' death extinguished both his criminal liability and civil liability based solely on the rape charge. However, civil liability could still be pursued through a separate civil action if it was predicated on something other than the criminal act, such as a contract. The private offended party also does not risk losing the ability to file a civil action due to prescription, as the statute of limitations is interrupted during the criminal case proceedings.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    44 views2 pages

    G.R. NO. 102007 SEPTEMBER 2, 1994 People of The Philippines VS. Rogelio Bayotas Facts

    Uploaded by

    Amicus Curiae
    Rogelio Bayotas was convicted of rape but died pending appeal of his conviction. The Supreme Court had to determine whether his death extinguished his criminal and civil liability. In its ruling, the Court held that Bayotas' death extinguished both his criminal liability and civil liability based solely on the rape charge. However, civil liability could still be pursued through a separate civil action if it was predicated on something other than the criminal act, such as a contract. The private offended party also does not risk losing the ability to file a civil action due to prescription, as the statute of limitations is interrupted during the criminal case proceedings.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    G.R. NO.

    102007 SEPTEMBER 2, 1994

    PEOPLE OF THE PHILIPPINES

    VS.

    ROGELIO BAYOTAS

    FACTS:

    Appellant Rogelio Bayotas was charged with rape and eventually convicted. Pending appeal of
    his conviction, Bayotas died at the National Bilibid Hospital due to his due to cardio respiratory arrest.
    Consequently, the Supreme Court in its Resolution, 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 his commission of the crime 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.

    ISSUE:

    Whether or Not the death of the accused pending appeal of his conviction extinguish his civil
    liability

    RULING:

    The Supreme Court held that the death of the accused Bayotas extinguished his criminal liability
    and civil liability based solely on the act complained of, i.e., rape. The Court ruled that: (1) death of the
    accused pending appeal of his conviction extinguishes his criminal liability as well as the civil liability
    based solely thereon; (2) the claim for civil liability survives notwithstanding the death of accused, if the
    same may also be predicated on a source of obligation other than delict, such as law, contracts, quasi-
    contracts or quasi-delicts; (3) where the civil liability survives, as explained in Number 2 above, an action
    for recovery therefor 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; and (4) the private offended party need
    not fear a forfeiture of his right to file this separate civil action by prescription, in cases where during the
    prosecution of the criminal action and prior to its extinction, the private-offended party instituted
    together therewith the civil action for in such case, the statute of limitations on the civil liability is
    deemed interrupted during the pendency of the criminal case.

    ALTERNATIVE RULING:

    The Court decided on this case through stating the cases of Castillo and Sendaydiego. In the
    Castillo case, the Court said that civil liability is extinguished only when death of the accused occurred
    before the final judgement. Judge Kapunan further stated that civil liability is extinguished because there
    will be “no party defendant” in the case. There will be no civil liability if criminal liability does not exist.
    Further, the Court stated “it is, thus, evident that… the rule established was that the survival of the civil
    liability depends on whether the same can be predicated on the sources of obligations other than delict.

    In the Sendaydiego case, the Court issued Resolution of July 8, 1977 where it states that civil liability will
    only survive if death came after the final judgement of the CFI of Pangasinan. However, Article 30 of the
    Civil Code could not possibly lend support to the ruling in Sendaydiego. Civil liability ex delicto is
    extinguished by the death of the accused while his conviction is on appeal. The Court also gave a
    summary on which cases should civil liability be extinguished, to wit:

    Death of the accused pending appeal of his conviction extinguishes his criminal liability as well as the
    civil liability based solely thereon. Therefore, Bayotas’s death extinguished his criminal and civil liability
    based solely on the act complained of.

    NOTE:

    SEYNANDIEGO VS. PEOPLE

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