Title
Bayos vs. Villaluz
Case
G.R. No. L-48982
Decision Date
Mar 30, 1979
Employees suspended without prior hearing on graft charges; Supreme Court ruled suspension improper, remanded case for proper hearing, lifting suspension.
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Case Digest (G.R. No. L-48982)

Facts:

  1. Parties Involved:

    • Petitioners: Carlos Bayos and Anacleto Matundan, employees of the Philippine National Railways.
    • Respondents: Honorable Judge Onofre A. Villaluz and the People of the Philippines.
  2. Charges Filed:

    • An Information was filed against the petitioners on August 15, 1978, for violation of Republic Act No. 3019, also known as the Anti-Graft and Corrupt Practices Act.
  3. Procedural Background:

    • The case was filed in the Circuit Criminal Court, Seventh Judicial District, presided over by Judge Onofre A. Villaluz.
    • Petitioners were arraigned, and on August 24, 1978, the respondent judge issued an Order suspending them from service until the termination of the case, pursuant to Section 13 of R.A. 3019.
  4. Petitioners' Argument:

    • Petitioners contended that the suspension Order was contrary to law and jurisprudence because it was issued without a hearing to determine the validity of the Information.
    • They relied on the Supreme Court's ruling in Luciano vs. Mariano (40 SCRA 187), which held that a hearing on the validity of the Information is a condition sine qua non for the issuance of a suspension order.
  5. Solicitor General's Comment:

    • The Office of the Solicitor General agreed with the petitioners, stating that the respondent judge failed to follow the guidelines set by the Supreme Court in Luciano vs. Mariano.
    • It recommended that the case be remanded to the lower court for a proper hearing on the validity of the Information.

Issue:

  1. Whether the suspension Order issued by the respondent judge without a prior hearing on the validity of the Information is valid under R.A. 3019 and prevailing jurisprudence.

Ruling:

The Supreme Court ruled in favor of the petitioners. It held that the suspension Order issued by the respondent judge was improper because it was issued without a prior hearing to determine the validity of the Information. The Court remanded the case to the lower court for a proper hearing in accordance with the guidelines set forth in Luciano vs. Mariano. Pending the hearing, the suspension Order of August 24, 1978, was lifted.

Ratio:

  1. Requirement of a Hearing:

    • Under Section 13 of R.A. 3019, a hearing to determine the validity of the Information is indispensable before a suspension order can be issued.
    • This requirement ensures that the accused is given an opportunity to challenge the validity of the charges against them before being subjected to the penalty of suspension.
  2. Jurisprudential Basis:

    • The Supreme Court reiterated its ruling in Luciano vs. Mariano, which established that a hearing on the validity of the Information is a mandatory prerequisite for the issuance of a suspension order.
    • The trial court must issue a show-cause order and conduct a hearing to determine the validity of the Information before suspending the accused.
  3. Remedy for Non-Compliance:

    • When a suspension order is issued without complying with the mandatory hearing requirement, the proper remedy is to remand the case to the lower court for a proper hearing.
    • The suspension order must be lifted pending the outcome of the hearing.


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