PEOPLE v BAYOTAS (236 SCRA 239) September 2, 1994 (Digest)

Extinction of Civil Liability

45. PEOPLE v BAYOTAS (236 SCRA 239) September 2, 1994 

G.R. No. 102007

Facts:

                Bayotas died on February 4, 1992 at the National Bilibid Hospital due to cardio respiratory arrest. Consequently, the Supreme Court in its Resolution of May 20, 1992 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 offense charged.

Issue: WON the death of the accused Bayotas extinguished his criminal liability and civil liability based solely on the act complained.

Held: Yes

Ratio:

                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.