People v. Asisclo Talaugon

Summary

The Supreme Court dismissed the criminal case against Asisclo Talaugon who was convicted of rape and sentenced to reclusion perpetua by the RTC, with the conviction affirmed by the Court of Appeals. During the pendency of his final appeal to the Supreme Court, Talaugon died in prison on May 25, 2022. Applying Article 89(1) of the Revised Penal Code, the Court ruled that criminal liability is totally extinguished by the death of the accused before final judgment. The Court dismissed the criminal case and declared it closed and terminated, but clarified that the victim may still pursue civil liability against Talaugon's estate based on sources other than delict under Article 1157 of the Civil Code. This case demonstrates the fundamental principle that death of the accused pending appeal extinguishes both criminal liability and civil liability ex delicto, while preserving potential civil remedies based on other legal grounds.