GR 30772; (October, 1971) (Digest)
G.R. No. L-30772 October 29, 1971
PHILIPPINE NATIONAL RAILWAYS, petitioner, vs. HON. FELIX R. DOMINGO and JUAN MAFE, respondents.
FACTS
Private respondent Juan Mafe, an employee of the Philippine National Railways (PNR), was charged with qualified theft for allegedly stealing a brass bearing. After trial, the respondent court acquitted Mafe on the ground that his guilt was not proven beyond reasonable doubt. The judgment of acquittal was promulgated on February 7, 1969.
Subsequently, Mafe filed a motion to amend the decision, alleging for the first time that he had been dismissed from PNR effective July 4, 1967, due to the same incident. He prayed that the court order his reinstatement with payment of back salaries. The respondent court, noting the absence of opposition from PNR at the hearing, granted the motion and issued an “amendatory decision” ordering Mafe’s immediate reinstatement with full back wages and benefits.
ISSUE
Whether a trial court, in a judgment acquitting an accused in a criminal case, has the jurisdiction to order his reinstatement to employment and the payment of back salaries.
RULING
The Supreme Court ruled that the respondent court acted without jurisdiction in issuing the amendatory decision. The legal logic is anchored on the limited scope of a criminal court’s authority. In a criminal proceeding, the judgment authorized by law is strictly confined to either an acquittal or a conviction, which may include the imposition of penalties and civil liability arising ex delicto from the criminal act itself, as provided in the Revised Penal Code.
The claim for reinstatement and back salaries, however, does not arise from the criminal act of theft. It is a separate and distinct cause of action rooted in employer-employee relations, potentially involving questions of due process in administrative dismissal, which are outside the issues joined by the plea of not guilty in the criminal case. The Court, citing established jurisprudence such as People v. Mañago and Manila Railroad Co. v. Baltazar, consistently held that a criminal court has no power to grant such relief. The entitlement to back salaries and reinstatement following an acquittal is not a matter that can be adjudicated within the criminal case; it must be pursued in the proper separate forum, whether civil or administrative. Therefore, the amendatory decision was a nullity for having been issued in excess of jurisdiction. The writs of certiorari and prohibition were granted.