Edit: I think I'm wrong and misremembering.
Edit: I think I'm wrong and misremembering.
Edit: https://support.apple.com/en-us/HT204306:
> Unless you made a backup before you forgot your passcode, there isn't a way to save your device's data. You'll need to erase your device, which deletes all of your data and settings.
Looks like the deceased had an iCloud backup of his iPhone, potentially unencrypted (i.e. without a password - Apple obviously encrypts this on their end). More in the iCloud security model: https://support.apple.com/en-us/HT202303
Edit 2: You can turn off iCloud backup altogether to avoid this (on an iPhone: Apple ID -> iCloud -> iCloud Backup -> Off).
In most cases though, a phone backup is an identical substitute for the phone itself.
Anyone care to confirm?