G.R. No. L-24940 December 26, 1969
The People of the Philippines, plaintiff-appellee, vs. Jose Saclao alias Pepe, defendant-appellant.

FACTS

Jose Saclao alias Pepe was found guilty of murder by the Court of First Instance of Guimba, Nueva Ecija in Criminal Case 99-G for the killing of Donato Ignacio. He was sentenced on June 8, 1965 to reclusion perpetua, ordered to indemnify the heirs of the victim in the amount of P6,000, and to pay the costs. He seasonably appealed the decision to the Supreme Court, where it was docketed as G.R. No. L-24940. During the pendency of the appeal, the Solicitor General filed a manifestation on December 16, 1969, informing the Court that the appellant, Jose Saclao, had died. The manifestation was supported by certifications from the Philippine Constabulary, the National Bureau of Investigation, and the Bureau of Prisons. These documents established that Jose Saclao was a detention prisoner who escaped from the PC Stockade at Camp Crame on September 8, 1969, and was slain on the same day in San Juan, Rizal. The records further showed he was the same person convicted of murder, had been committed to the National Penitentiary on July 1, 1965, and had previously escaped from there on August 11, 1965. A death certificate and a postmortem examination certificate were also submitted.

ISSUE

Whether the criminal appeal pending before the Supreme Court should be dismissed in light of the death of the accused-appellant, Jose Saclao.

RULING

Yes. The Supreme Court dismissed the case. The Court found it established from the official certifications and documents submitted by the Solicitor General that Jose Saclao, the defendant-appellant, was dead. Consequently, the criminal action against him was extinguished by his death. The case was dismissed, and the costs were ordered de officio.