GR 200030; (April, 2012) (Digest)
G.R. No. 200030 ; April 18, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. NELSON BAYOT y SATINA, Accused-Appellant.
FACTS
Accused-appellant Nelson Bayot y Satina was charged with the rape of AAA. The Regional Trial Court convicted him, a decision affirmed by the Court of Appeals, which modified the civil liabilities. The prosecution established that on September 17, 1997, through force and intimidation, appellant had carnal knowledge of AAA against her will. AAA’s testimony was straightforward and corroborated by medical findings of a vaginal contusion indicative of forceful intrusion. Appellant’s defense of a consensual “sweetheart” relationship was rejected by both lower courts as a self-serving claim unsupported by credible evidence and contradicted by AAA’s immediate reporting of the crime.
During the pendency of his appeal before the Court of Appeals, the Penal Superintendent of the New Bilibid Prison informed the court that appellant had died on December 4, 2004. Despite this, the Public Attorney’s Office pursued the appeal to the Supreme Court.
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 the accused-appellant during the pendency of his appeal totally extinguishes his criminal liability and the civil liability arising solely from the crime (civil liability ex delicto). This is pursuant to Article 89(1) of the Revised Penal Code, which states that death of the convict extinguishes personal penalties, and pecuniary penalties are extinguished if death occurs before final judgment. The Court, applying the doctrine in People v. Bayotas, held that death pending appeal nullifies the criminal action and any civil liability based exclusively on the offense.
Consequently, the appeal is dismissed. The criminal case against appellant is declared closed, and his civil liability arising from the rape is extinguished. The Court clarified that only the civil liability ex delicto is extinguished. Any independent civil liability, such as one arising from a quasi-delict, contract, or other sources of obligation under Article 1157 of the Civil Code, may survive and can be pursued in a separate action. However, in this case, no such independent civil action was instituted or reserved.