People vs. Abungan, 341 SCRA 258 (2000) Digest

Extension of Criminal Liability

35. People vs. Abungan, 341 SCRA 258 (2000)

Student: G-one T. Paisones

Professor: Atty. Cisco Franz S. Maclang

Facts:

                Pedro Abungan assailing the Decision  of the RTC of Villasis, Pangasinan,  in Criminal Case, in which he was convicted of murder, sentenced to reclusion perpetua, and ordered to pay P50,000 as indemnity to the heirs of the deceased.

However, Abungan had died on July 19, 2000 at the NBP Hospital. 

Issue:

                WON the effect of Appellant Abungan's death on the case and on the appeal extinguished his criminal and civil liability.

Held:

                Yes.

Ratio:

                The death of appellant on July 19, 2000 during the pendency of his appeal extinguished his criminal as well as his civil liability, based solely on delict (civil liability ex delicto).