People v. Lagutan
REITERATIONFacts
1. The Antecedents: Pedro Lagutan, the Municipal Treasurer of Lilo-an, Leyte, was charged with falsification of documents and malversation of public funds in two separate criminal cases filed on January 15, 1937. The cases were consolidated for trial. 2. Procedural History: The trial court jointly heard both cases and issued a single decision on July 17, 1937, acquitting the accused. Following his indictment, Lagutan was suspended from his position and ceased receiving his salary. He passed away sometime after the acquittal. On September 14, 1938, his widow, Paciencia Penaso, filed a motion requesting the court to order the Municipal Treasurer of Lilo-an to pay her the salaries her deceased husband did not receive during his suspension until the date of his acquittal. The trial court granted this motion on September 19, 1938, ordering the payment. The Provincial Fiscal objected to this order and filed the present appeal. 3. The Petition: The People of the Philippines, represented by the Solicitor General, appealed the trial court's order, arguing that the court lacked jurisdiction to issue such an order. They contended that the court erred in not denying the widow's petition and in ordering the payment of accumulated salaries. The appellant insisted that any remedy the widow might have lies with the administrative authorities, not the court. The appeal specifically challenges the trial court's authority to grant payment of salaries during suspension, asserting that such power is not inherent to the court's jurisdiction nor provided by any relevant statute, except for specific provisions concerning municipal police members.
Issue(s)
Whether the Court of First Instance has jurisdiction to order the payment of salaries of a suspended municipal official who was subsequently acquitted. Whether the inherent powers of a court include ordering the payment of salaries of a suspended official.
Ruling
The Supreme Court ruled that the Court of First Instance lacked jurisdiction to issue the order for the payment of accumulated salaries. The petition filed by the appellee was denied, and the appealed order was revoked without special pronouncement as to costs.
Ratio Decidendi
On the Issue of Jurisdiction to Order Payment of Salaries: The Supreme Court held that Courts of First Instance only acquire jurisdiction over matters conferred upon them by the Constitution or law. In this case, the appellee's counsel failed to cite any law empowering the court to grant the salaries that the accused Lagutan failed to receive during his suspension until his acquittal. The Court clarified that Article 2272, penultimate paragraph, of the Revised Administrative Code, which authorizes courts to order the payment of salaries of an accused official, refers exclusively to the Chief and members of the Municipal Police. Furthermore, Article 2192 of the Revised Administrative Code, as amended, provides that if a municipal official suspended during an investigation is exonerated or reinstated, the Chief of Department may order the payment of part or all of his salary accumulated during suspension. This indicates that the authority to order such payments rests with the administrative head, not the court. On the Issue of Inherent Powers of the Court: The Supreme Court rejected the appellee's argument that the order was legal because it was issued in the exercise of the court's inherent powers, citing Article 11 of the Code of Civil Procedure. The Court stated that ordering the payment of salaries of a municipal treasurer corresponding to the period of his suspension until his acquittal does not fall within the inherent powers of a court. It is not an accessory remedy authorized by the Revised Penal Code or any other existing law. Therefore, the court erred in issuing the order based on such grounds.
Main Doctrine
The Supreme Court held that a Court of First Instance lacks the jurisdiction to order the payment of accumulated salaries of a municipal official suspended during the pendency of criminal charges against him, even if he was subsequently acquitted. Such claims are not within the inherent powers of a court, nor are they authorized as an accessory remedy under existing laws. The proper recourse for the official's heirs is to pursue the claim through the administrative head of the department to which the deceased official belonged.