G.R. No. 186382 , April 5, 2010.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. DOMINGO PANITERCE, Accused-Appellant.

FACTS

Accused-appellant Domingo Paniterce was charged with four counts of rape against his daughter AAA (Criminal Case Nos. 6076, 6077, 6078, 6079) and two counts of rape against his other daughter BBB (Criminal Case Nos. 6080, 6081). The Regional Trial Court (RTC) of Iriga City found him guilty beyond reasonable doubt of the crimes of Rape and Acts of Lasciviousness. The Court of Appeals affirmed the RTC judgment with modifications. Paniterce appealed to the Supreme Court. During the pendency of his appeal, the Assistant Director for Prisons and Security of the Bureau of Corrections informed the Court that Paniterce had died on August 22, 2009, at the New Bilibid Prison Hospital.

ISSUE

What is the effect of the death of the accused-appellant during the pendency of his appeal on his criminal and civil liabilities?

RULING

The death of accused-appellant Domingo Paniterce during the pendency of his appeal extinguished his criminal liability and his civil liability arising solely from the crimes (civil liability ex delicto). Applying Article 89(1) of the Revised Penal Code and the guidelines in People v. Bayotas, the Court held that since Paniterce died before a final judgment of conviction was rendered, his criminal liability was totally extinguished as to personal penalties, and his pecuniary penalties (civil liability based solely on the crime) were also extinguished. Consequently, the appealed Decision of the Court of Appeals became ineffectual. The Court set aside the Court of Appeals Decision and dismissed the criminal cases.