Philippine National Railways v. Domingo
REITERATIONFacts
The Antecedents: Private respondent Juan Mafe, an employee of Philippine National Railways (PNR), was charged with qualified theft for stealing a brass bearing valued at P45.00. The prosecution presented evidence including the apprehension of Mafe with the stolen item, his extrajudicial confession, and corroborating testimonies. Mafe disowned criminal intent, claiming he was returning the item, and repudiated his confession, alleging coercion. Procedural History: The trial court acquitted Mafe on January 18, 1969, ruling that his guilt was not established beyond reasonable doubt. After promulgation, Mafe filed a motion to amend the decision, seeking reinstatement with back salaries and restoration of rights, citing his dismissal from PNR for dishonesty related to the same incident. The PNR board had resolved to dismiss him with prejudice to reinstatement and to forego prosecution. The Petition: The respondent court, despite PNR's motion to set aside the amendatory decision for lack of jurisdiction and due process, issued an "amendatory decision" on March 27, 1969, ordering Mafe's reinstatement with full back salaries and restoration of benefits. PNR filed a petition for certiorari and prohibition with the Supreme Court, arguing the respondent court lacked jurisdiction to issue the amendatory decision. A preliminary injunction was issued.
Issue(s)
Whether the respondent court, in rendering a judgment of acquittal in a criminal case, may properly decree the payment of salaries during the accused employee's suspension and order reinstatement. Whether the respondent court had the jurisdiction to issue an "amendatory decision" after the original judgment of acquittal had become final.
Ruling
The Supreme Court granted the petition, annulling and setting aside the amendatory decision and order of the respondent court, and made the writ of preliminary injunction permanent. The Court ruled that the respondent court acted without jurisdiction in issuing the amendatory decision.
Ratio Decidendi
On the issue of the trial court's authority to order reinstatement and back salaries upon acquittal: The general rule, consistently pronounced by the Supreme Court, is that a trial court in a criminal case has no authority to decree the payment of salaries during the period of suspension or to order reinstatement upon acquittal. This principle was established in cases such as People vs. Mañago, Manila Railroad Co. vs. Baltazar, and People vs. Daleon. The rationale is that the only issue joined in a criminal case is whether the accused committed the crime charged. The judgment authorized is either conviction with indemnity and accessory penalties or acquittal. The matter of salary during suspension or reinstatement falls outside the scope of the criminal case and pertains to administrative or civil remedies. The acquittal in a criminal case does not automatically absolve an employee from administrative liability, as administrative proceedings require only a preponderance of evidence, unlike the proof beyond reasonable doubt required in criminal cases. Therefore, relief for reinstatement and back salaries must be sought in the proper administrative or civil action prescribed by law, not within the criminal case itself. On the issue of the respondent court's jurisdiction to issue an "amendatory decision" after finality of judgment: The respondent court acted without jurisdiction when it issued its "amendatory decision" dated March 27, 1969. The original decision of acquittal, having been promulgated on February 7, 1969, became immediately final. A judgment of acquittal, once final, can no longer be recalled or modified by the same court. The court loses its jurisdiction over the case after the judgment becomes final. Therefore, any subsequent order or decision attempting to amend or modify the final judgment, such as the order for reinstatement and back salaries, is void for having been issued without jurisdiction. The court's power is limited to the issues joined in the criminal case, and the question of administrative liability or entitlement to back wages was not an issue in the criminal proceeding.
Main Doctrine
A trial court, in a criminal case where the accused employee is acquitted, has no authority to order the employee's reinstatement or payment of back salaries. Such relief must be sought in a separate administrative or civil action, as acquittal in a criminal case does not necessarily absolve an employee from administrative liability.