People v. Rogelio Bayotas y Cordova

Summary

This landmark Supreme Court En Banc decision resolved the long-standing issue of whether civil liability survives the death of an accused pending appeal of his criminal conviction. Bayotas was convicted of rape but died during appeal. The Court ruled that death of the accused pending appeal extinguishes both criminal liability and civil liability based solely on the criminal act (ex delicto). The Court overruled People v. Sendaydiego and established that civil liability survives only if it can be based on sources other than delict under the Civil Code. Where civil liability survives, it must be pursued through separate civil action against the estate or executor/administrator depending on the source of obligation. This decision clarified the application of Article 89 of the Revised Penal Code and provided definitive guidance on handling civil liability when accused dies pending appeal, establishing the principle 'Mors Omnia Solvi' (Death dissolves all things) for purely delictual civil liability.