GR 106296; (July, 1996) (Digest)
G.R. No. 106296 July 5, 1996
ISABELO T. CRISOSTOMO, petitioner, vs. THE COURT OF APPEALS and the PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Isabelo Crisostomo was the President of the Philippine College of Commerce (PCC). In 1976, he was preventively suspended and criminally charged with violations of the Anti-Graft and Corrupt Practices Act. On April 1, 1978, Presidential Decree No. 1341 converted the PCC into the Polytechnic University of the Philippines (PUP). Dr. Pablo T. Mateo Jr., who had been designated as officer-in-charge, was later appointed as the President of PUP for a six-year term starting March 28, 1980. Crisostomo was acquitted of all criminal charges on July 11, 1980. The acquitting court ordered his reinstatement as President of the PCC, now PUP, and payment of back salaries.
ISSUE
Whether the acquitting court could validly order the reinstatement of Crisostomo to the presidency of PUP and the payment of his salaries and benefits for the entire period of his suspension.
RULING
No. The Supreme Court affirmed the Court of Appeals’ decision setting aside the reinstatement order and limiting the payment of back salaries. The legal logic is anchored on the legal effects of P.D. No. 1341. The decree did not merely change the name of the institution; it created a new juridical entity, the PUP, with a new charter. Section 6 of the decree provides that the President of the University shall be appointed by the President of the Philippines upon recommendation of the Secretary of Education for a term of six years. This new appointment process superseded Crisostomo’s old appointment. Consequently, his term as President of the PCC was legally terminated upon the conversion and the subsequent appointment of Dr. Mateo as PUP President in 1980. His right was thus converted into a claim for separation pay under Section 7 of the decree, not reinstatement. Therefore, the trial court’s order for reinstatement was a grave abuse of discretion, as it compelled the performance of an act—appointment to a statutory position—that is vested by law in the discretion of the President. Payment of salaries was correctly limited only up to March 28, 1980, the date his term legally ended with Mateo’s appointment.