G.R. No. L-48352 January 3, 1987
THE ACTING DIRECTOR OF PRISONS, petitioner, vs. HON. ONOFRE A. VILLALUZ, as Judge of the Circuit Criminal Court of Pasig, Metro Manila, CLEMENTE DOMINGO, JR., EDUARDO ROXAS, JUANITO LEOPANDO, MIGUEL PALAMOS, VERGEL PONCIANO and DEOGRACIAS LIZARDO, respondents.

FACTS

Private respondents, prison guards at the New Bilibid Prison, were charged with Murder. Pending trial, they were suspended and subsequently dismissed from service pursuant to Letter of Instructions No. 14-A. The Circuit Criminal Court acquitted them on May 15, 1974, for failure of the prosecution to prove guilt beyond reasonable doubt. Upon motion of the acquitted guards, the court amended its resolution on June 4, 1974, ordering their reinstatement and payment of back salaries for the suspension period. The petitioner reinstated them but refused to authorize back pay, forwarding the order to the Secretary of Justice, who denied it. The trial court subsequently issued orders in 1978 directing compliance with the 1974 order, which the petitioner continued to resist.

ISSUE

The sole issue is whether the trial court, in a criminal case for Murder resulting in acquittal, has jurisdiction to order the reinstatement of the accused to their former government positions and the payment of their back salaries.

RULING

The Supreme Court ruled that the trial court acted without jurisdiction. The legal logic is anchored on the limited scope of a criminal court’s authority. A criminal case is solely for the determination of the criminal liability of the accused. The judgment that a criminal court is legally authorized to render is confined to either acquittal or conviction, including the corresponding civil liability for indemnity and accessory penalties provided by law. The remedy of reinstatement and recovery of back salaries, arising from an administrative dismissal, is not a consequence that flows from a judgment of acquittal in a criminal prosecution. Such relief properly pertains to a separate civil or administrative action. The Court distinguished cited cases involving acquitted public officials claiming back salaries, noting those claims arose from appeals in civil or administrative proceedings, not from the criminal case itself. Furthermore, the dismissal of the respondents was pursuant to a valid presidential directive (LOI No. 14-A), and there was no showing of bad faith or grave abuse of discretion in their removal that would warrant back pay. Therefore, the challenged orders were set aside for having been issued without jurisdiction.