People v. Pedro Abungan Alias "Pedring

Summary

Pedro Abungan was convicted of murder and sentenced to reclusion perpetua by the Regional Trial Court. While his appeal was pending before the Supreme Court, he died on July 19, 2000. The Supreme Court applied the doctrine in People v. Bayotas and held that his death extinguished both his criminal liability and civil liability arising from the delict (ex delicto). The Court dismissed the criminal case and set aside the trial court's decision, clarifying that while criminal and civil liability ex delicto are extinguished by death during appeal, victims may still pursue separate civil actions against the deceased's estate based on other sources of obligation under Article 1157 of the Civil Code.