Crisostomo v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Isabelo T. Crisostomo was appointed President of the Philippine College of Commerce (PCC) in 1974. He was later charged with various administrative offenses and violations of R.A. No. 3019, R.A. No. 992, and R.A. No. 733. Consequently, he was preventively suspended on October 22, 1976. On April 1, 1978, Presidential Decree No. 1341 converted the PCC into the Polytechnic University of the Philippines (PUP). On July 11, 1980, petitioner was acquitted of the criminal charges, and the court ordered his reinstatement to the position of President of the PCC, now known as PUP, and payment of salaries and benefits during his suspension. Administrative cases against him were dismissed. Procedural History: Petitioner filed a motion for execution of the judgment, which was granted by the Regional Trial Court (RTC), issuing a partial writ of execution for his reinstatement and payment of benefits. However, President Corazon C. Aquino appointed Dr. Jaime Gellor as acting president of PUP. The RTC reiterated its order for petitioner's reinstatement, and a writ of execution was issued. The sheriff installed petitioner as President, though Dr. Gellor did not vacate. The People of the Philippines filed a petition for certiorari and prohibition with the Court of Appeals (CA), assailing the RTC orders. The CA issued a temporary restraining order enjoining petitioner from acting as president and further proceedings. On July 15, 1992, the CA rendered a decision setting aside the RTC orders for reinstatement and limiting the payment of salaries and benefits to those accruing before the conversion of PCC to PUP, remanding the case to the RTC for determination of the correct amounts due. The Petition: Petitioner seeks review of the CA decision, arguing that the conversion of PCC to PUP did not abolish the former, and thus he could be reinstated. He contends that the PUP is merely a continuation of the PCC. The Supreme Court, however, noted that Presidential Decree No. 1437, promulgated on June 10, 1978, fixed the term of office for presidents of state universities and colleges at six years, renewable, and authorized the President to terminate incumbents not reappointed, entitling them to retirement or separation pay.
Issue(s)
Whether the conversion of the Philippine College of Commerce (PCC) into the Polytechnic University of the Philippines (PUP) under P.D. No. 1341 resulted in the abolition of the PCC and the expiration of petitioner's term as its president; and the interpretation of "stand transferred" in P.D. No. 1341. Whether petitioner is entitled to reinstatement as President of the PUP and payment of salaries and benefits during his suspension, including those accruing after the conversion of PCC to PUP; and the effect of P.D. No. 1437 on reinstatement. Whether Presidential Decree No. 1437, which fixed the term of office for university presidents, affects petitioner's right to reinstatement; and the Court of Appeals' ruling regarding different entities.
Ruling
The Supreme Court modified the decision of the Court of Appeals. It affirmed that the conversion of PCC to PUP did not abolish the institution but merely changed its status. However, it ruled that reinstatement of petitioner to the position of president of PUP could not be ordered due to the promulgation of P.D. No. 1437, which fixed the term of office for university presidents and allowed for the termination of incumbents. Petitioner is entitled only to retirement or separation pay. The payment of salaries and benefits is limited to those accruing up to March 28, 1980, when petitioner's term was effectively terminated by the appointment of Dr. Pablo T. Mateo Jr. as president of PUP.
Ratio Decidendi
On the conversion of PCC to PUP and its effect on petitioner's term; and the interpretation of "stand transferred" in P.D. No. 1341: The Court held that Presidential Decree No. 1341, which converted the Philippine College of Commerce (PCC) into the Polytechnic University of the Philippines (PUP), did not abolish the PCC, but was a change in academic status. The PUP was a continuation of the PCC's corporate existence. The Court clarified that "stand transferred" did not imply the creation of a new entity receiving assets from an abolished one, but rather that the assets of the institution under its new name (PUP) were to be understood as continuing to belong to it. This reinforced the idea of continuity rather than abolition. On entitlement to salaries and benefits; and the effect of P.D. No. 1437 on reinstatement: Despite the continuity of the institution, the Court found that reinstatement was no longer possible due to the promulgation of Presidential Decree No. 1437. This decree established a fixed term of six years for the heads of state universities and colleges and authorized the President of the Philippines to terminate the terms of incumbents who were not reappointed. Consequently, the Court ruled that petitioner's entitlement to salaries and benefits during his suspension was limited to the period up to March 28, 1980, the date his term was terminated by the appointment of Dr. Mateo. On whether Presidential Decree No. 1437, which fixed the term of office for university presidents, affects petitioner's right to reinstatement; and the Court of Appeals' ruling regarding different entities: The Court acknowledged the Court of Appeals' reasoning that PUP and PCC were different entities due to expanded objectives, different appointment processes for the president, and a different composition of the governing board. However, the Supreme Court clarified that these changes, while significant for the new university structure, did not equate to the abolition of the original institution. The Court emphasized that only an express declaration by the lawmaking authority would signify abolition and the creation of a new entity. P.D. No. 1437, Section 7, provided that incumbents whose terms were terminated were entitled to full retirement benefits if they had served for at least twenty years, or one month's pay for every year of service if less than twenty years. This indicated that reinstatement was not the remedy, but rather separation benefits.
Main Doctrine
While the conversion of an institution does not necessarily abolish it, the promulgation of a new law fixing the term of office for its head and allowing for the termination of incumbents can render reinstatement impossible, entitling the former head only to retirement or separation pay.