People v. Bernard Galang

Summary

The Supreme Court dismissed a criminal case for carnapping with homicide against Bernard Galang due to his death during the pendency of his appeal. Originally convicted by the RTC and affirmed by the CA, Galang died on June 13, 2020 from congestive heart failure with COVID-19 as suspect underlying cause while his case was pending before the Supreme Court. Applying Article 89 of the Revised Penal Code and the Bayotas doctrine, the Court ruled that the accused's death extinguished both his criminal liability and civil liability ex delicto. However, the Court clarified that the victim's heirs may still pursue a separate civil action against Galang's estate based on other sources of obligation under the Civil Code, ensuring that civil remedies remain available despite the termination of the criminal case.