Practice question
An accused dies pending appeal. Besides an offense-based claim, the claimant has an independently established contractual obligation arising from the same transaction. The heirs assert that Bayotas extinguishes every claim whatever its source. Which is correct?
- All obligations automatically disappear
- The contract automatically proves criminal guilt
- A claim truly based on an independent source may survive and must follow the proper civil and estate procedures
- The heirs must be imprisoned until payment
- The criminal appeal continues against the deceased without limitation
Legal references
- https://lawphil.net/statutes/acts/act1930/act_3815_1930.html — RPC Article 89(1): death, personal penalties and pecuniary penalties before final judgment.
- https://lawphil.net/judjuris/juri1994/sep1994/gr_102007_1994.html — People v. Bayotas, G.R. 102007, September 2, 1994, main decision: death pending appeal and separate sources of civil obligations.
- https://lawphil.net/courts/rules/rc_110-127_crim.html — Rule 111 section 4: death during criminal proceedings, surviving independent civil claims and proper representation.
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