G.R. No. 175784; August 25, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JAIME AYOCHOK y TAULI, Accused-Appellant.

FACTS

Accused-appellant Jaime Ayochok was charged with Murder for the shooting death of SPO1 Claudio Caligtan. The Regional Trial Court found him guilty beyond reasonable doubt, sentencing him to reclusion perpetua and ordering him to pay various damages to the victim’s heirs. The Court of Appeals affirmed the conviction with modifications to the awarded amounts. Ayochok appealed the decision to the Supreme Court.
During the pendency of his appeal, the Court received official notification that Ayochok had died on January 15, 2010. This supervening event prompted the Court to address the legal effect of the accused’s death before final judgment on his criminal and civil liabilities.

ISSUE

What is the effect of the death of the accused pending appeal on his criminal liability and the civil liability arising from the crime?

RULING

The death of the accused pending appeal extinguishes both his criminal liability and the civil liability arising exclusively from the crime (civil liability ex delicto). The legal logic is anchored on Article 89(1) of the Revised Penal Code, which states that criminal liability is totally extinguished by the death of the convict, with pecuniary penalties also extinguished if death occurs before final judgment. Applying the guidelines established in People v. Bayotas, the Court held that since Ayochok died before a final judgment of conviction was rendered, his death totally extinguished his personal criminal penalties.
Consequently, his civil liability based solely on the crime of murder was likewise extinguished. The civil liability referred to here is that which is intrinsically linked to the criminal act. The appealed decision of the Court of Appeals, being non-final, became ineffectual. The Court emphasized that it was therefore unnecessary to review the merits of the appeal on the conviction itself. The criminal case was dismissed.