Acting Director of Prisons v. Villaluz
REITERATIONFacts
The Antecedents: Private respondents, who were prison guards at the New Bilibid Prison, were charged with Murder in Criminal Case No. CCC-VII-1406. Pending trial, they were suspended and subsequently dismissed from the service by the Secretary of Justice, pursuant to Letter of Instructions No. 14-A. Procedural History: The Circuit Criminal Court of Pasig, Metro Manila, promulgated a Resolution on May 15, 1974, acquitting the accused for failure of the prosecution to prove their guilt beyond reasonable doubt. On motion of the private respondents, the court amended its Resolution on June 4, 1974, to include their reinstatement to their former positions and the payment of their back salaries during the period of suspension. The Acting Director of the Bureau of Prisons reinstated the respondents but denied the payment of back salaries, forwarding the order to the Secretary of Justice, who denied it. Subsequently, the respondent court issued an Order on October 3, 1977, stating that the Acting Director of Prisons was bound by its order to pay back salaries, as it had become final and executory. The Acting Director again forwarded this to the Secretary of Justice, who reiterated his denial. The respondents then filed a motion to declare the Acting Director in contempt. Without ruling on the contempt motion, the respondent court issued an Order on January 26, 1978, directing compliance with the June 4, 1974 Order. The Acting Director filed a motion for reconsideration, which was denied by the respondent court in an Order dated April 21, 1978. The Petition: The Acting Director of Prisons filed a petition for certiorari and prohibition with preliminary injunction, seeking to set aside the orders of the respondent court directing the reinstatement and payment of back salaries.
Issue(s)
Whether the respondent Court acted within its jurisdiction when, in an order acquitting the accused from criminal liability, it at the same time directed the Acting Director of Prisons to reinstate said accused to their former positions and to authorize the payment of their supposed back salaries during the period of their alleged suspension. Whether the private respondents, as prison guards, are entitled to payment of salaries during their suspension, considering they were dismissed from the service pursuant to Letter of Instructions No. 14-A.
Ruling
The petition is GRANTED. The Orders of the Respondent Court dated June 4, 1974, January 26, 1978, and April 21, 1978, are SET ASIDE.
Ratio Decidendi
On the issue of jurisdiction to order reinstatement and back salaries: The Court held that the issue of reinstatement had become moot and academic because the private respondents had already been reinstated to their former positions. However, the Court ruled that it is not within the jurisdiction of the respondent Court to order the payment of salaries of respondents during the pendency of the criminal case filed against them. The Court reiterated its ruling in People v. Daleon, which held that a trial court, in a criminal action where the accused is acquitted, is without power to order the payment of his salary during the period of his suspension. The relief for back salaries must be sought in a proper administrative or civil action, not within the same criminal case. On the entitlement to back salaries: The Court found that Republic Act No. 557, which provides for back salaries in case of acquittal, applies only to provincial guards, city police, or municipal police with civil service eligibility, and not to prison guards. Therefore, the Noremor case, which cited RA 557, could not be invoked by the respondents. Furthermore, the Court noted that the respondents were dismissed from the service pursuant to Letter of Instructions No. 14-A. In the absence of proof that the dismissal was tainted with bad faith or grave abuse of discretion, they are not entitled to back salaries. The records showed that the dismissal was motivated by compliance with LOI No. 14-A, not by ill will or personal malice, and LOI No. 647 does not authorize payment of backwages of reinstated employees.
Main Doctrine
A trial court, in acquitting an accused from a criminal charge, is without power to order the payment of his salary during the period of his suspension, as the relief for back salaries must be sought in a proper administrative or civil action, not within the same criminal case.