People v. Bbb

Summary

BBB was convicted of Qualified Statutory Rape by the RTC and CA. While his appeal was pending before the Supreme Court, BBB died on January 10, 2022 at New Bilibid Prison Hospital. The Supreme Court applied established doctrine that death of the accused during appeal extinguishes criminal liability and civil liability arising solely from the criminal offense (ex delicto). However, the Court clarified that civil liability based on other sources under Article 1157 of the Civil Code may survive, and the victim AAA may file a separate civil action against BBB's estate. The appeal was dismissed, the CA decision set aside, and the case declared closed and terminated due to the supervening death of the accused-appellant.