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    Ethics Case

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    Ethics case

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    Ethics Case

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    audreyjoyce2022
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    © All Rights Reserved
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    Title Interpretation of "Final Judgment"

    People vs. Bayotas y Cordova The court examined the term "final judgment" and referred to legal precepts and
    opinions from the Code of 1870.
    Case Decision Date It concluded that "final judgment" refers to a judgment that is definite and confirmed,
    G.R. No. 102007 Sep 2, 1994
    and prior to that, there is no determination of guilt or liability.

    In the case of People v. Bayotas y Cordova, the Supreme Court ruled that the death of Therefore, the court held that the civil liability is extinguished if the accused dies
    the accused pending appeal extinguishes both his criminal and civil liability, unless the before final judgment.
    civil liability can be based on sources of obligations other than the offense committed.
    Analysis of Previous Cases
    The court discussed other cases that followed the ruling in People v. Castillo, which
    Case Summary (G.R. No. 102007) dismissed the appeal due to the death of the accused pending appeal.
    Case Background and Parties Involved However, the court noted that there were subsequent cases that ruled differently,
    allowing the civil liability to survive.
    The case of People v. Bayotas y Cordova involved Rogelio Bayotas y Cordova, who was
    charged with Rape and convicted on June 19, 1991. The court analyzed these cases and concluded that they deviated from the original
    ruling and were not supported by the law.
    Pending appeal of his conviction, Bayotas died on February 4, 1992.
    The Supreme Court dismissed the criminal aspect of the appeal but required the Reversal of Decision and Ruling
    Solicitor General to comment on Bayotas' civil liability arising from the offense. The court re-examined its own decision in People v. Castillo and concluded that it
    should revert to the old ruling.
    Arguments Presented
    It emphasized that the final determination of the criminal liability is a condition
    The Solicitor General argued that the death of the accused did not extinguish his civil
    precedent to the prosecution of the civil action.
    liability, relying on a previous case.
    Therefore, when the criminal action is extinguished by the death of the accused
    The counsel for the accused argued that the death of the accused extinguishes both his
    pending appeal, the civil action cannot survive.
    criminal and civil penalties.
    The court summarized its ruling, stating that the death of the accused pending appeal
    Main Issue: Extinguishment of Civil Liability extinguishes his criminal liability and the civil liability based solely on the offense
    The main issue in this case was whether the death of the accused pending appeal committed.
    extinguishes his civil liability. The claim for civil liability survives if it can be based on sources of obligations other
    The Supreme Court referred to the previous case of People v. Castillo, which settled than delict.
    this issue in the affirmative. If the civil liability survives, it must be pursued through a separate civil action.
    Under Article 89 of the Revised Penal Code, criminal liability is totally extinguished by The statute of limitations on the civil liability is deemed interrupted during the
    the death of the convict, and as to pecuniary penalties, liability is extinguished only pendency of the criminal case if the civil action was instituted together with the
    when the death occurs before final judgment. criminal action.
    The court concluded that the criminal liability of Bayotas was extinguished, but the Based on these rules, the court dismissed the appeal of Bayotas and held that his death
    civil liability posed a problem. extinguished both his criminal and civil liability.

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