People v. Manago
REITERATIONFacts
1. The Antecedents: Lazaro Manago was charged with malversation of public funds. Following his indictment, he was suspended from his office. 2. Procedural History: Manago was acquitted of the malversation charge on July 30, 1937. Subsequently, he filed a petition with the trial court seeking a supplemental decision for the payment of his salary during the period of his suspension. The trial court denied this petition, leading to the present appeal. 3. The Petition: The appellant seeks review of the trial court's order denying his petition for payment of salary during suspension. He argues that his acquittal in the criminal case should entitle him to back pay. The Supreme Court is asked to determine if such relief can be granted in a supplemental decision and if the petition was timely filed, considering it was presented two years after the original judgment.
Issue(s)
Whether the trial court may, in a judgment of acquittal in a criminal case for malversation, order the payment of the suspended employee's salary during the period of suspension. Whether a final judgment may be modified by a supplemental petition to include a relief not originally contemplated therein.
Ruling
The Supreme Court affirmed the order of the trial court denying the petition. The Court held that the petition was rightly denied.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petition was rightly denied because, in a criminal proceeding, the judgment authorized by law is either one of acquittal or conviction with indemnity and accessory penalties. The payment of salary of an employee during the period of suspension cannot, as a general rule, be properly decreed by the trial court in a judgment of acquittal. Such matters typically fall under the purview of the head of the department concerned, who has the discretion to grant or deny such claims, as provided for in Section 260 of the Revised Administrative Code. Therefore, the trial court exceeded its authority by attempting to order the payment of salaries in a criminal judgment of acquittal. On Issue 2: The Supreme Court further ruled that the petition was filed after the lapse of two years from the rendition of the judgment, which had already become final. The effect of granting the petition would be to modify a final judgment by adding thereto a relief that was not originally contemplated within the scope of the original proceedings. The Court emphasized that such modification of a final judgment is contrary to law and settled jurisprudence. Once a judgment becomes final and executory, it can no longer be altered or amended, except for clerical errors or upon grounds provided by law, none of which were present in this case. The principle of immutability of judgments was strictly applied.
Main Doctrine
The Supreme Court affirmed the denial of a petition seeking payment of salary during suspension following an acquittal in a malversation case. The Court held that a judgment of acquittal in a criminal proceeding, as a general rule, does not authorize the decree of payment of salary during suspension; this power devolves upon the head of the department concerned and is discretionary. Furthermore, the petition was filed after the judgment had become final, and modifying it to include the salary claim would constitute an impermissible alteration of a final judgment.