Phoenix Downs doesn't revive characters, neither "Life" or "Life2", they bring K.O'd characters back to fighting condition. K.O ≠ Death (even the spell "Death", doesn't KILL, it K.O's) All characters that REALLY died on the series (Minwu, Sage Tellah, Galuf, General Leo, Aeris, just to mention some) didn't come back to life with a Phoenix Down.