Case Digest (G.R. No. 106296)
Facts:
In Isabelo T. Crisostomo vs. Court of Appeals and the People of the Philippines, petitioner Isabelo T. Crisostomo was appointed President of the Philippine College of Commerce (PCC) on July 17, 1974. While in office, he faced two sets of administrative complaints and three criminal informations under Section 3(e) of R.A. No. 3019 for alleged misappropriation of construction materials, private use of a government driver, and appropriation of a bahay kubo intended for the PCC. On October 22, 1976, he was placed under preventive suspension pursuant to R.A. No. 3019, Section 13, and Dr. Pablo T. Mateo Jr. was designated officer-in-charge and later Acting President. On April 1, 1978, P.D. No. 1341 converted the PCC into the Polytechnic University of the Philippines (PUP), expanding its objectives, structure, and curricular offerings. Dr. Mateo continued as head and was appointed PUP President for a six-year term on March 28, 1980. On July 11, 1980, the Circuit Criminal Court of ManilCase Digest (G.R. No. 106296)
Facts:
- Appointment and Charges
- Petitioner Isabelo T. Crisostomo was appointed President of the Philippine College of Commerce (PCC) on July 17, 1974 by the President of the Philippines.
- Two sets of cases were filed against him during his incumbency:
- Administrative cases for illegal use of government vehicles, misappropriation of materials, oppression, nepotism, grave misconduct and dishonesty, referred to the Office of the Solicitor General.
- Criminal charges under R.A. No. 3019 (Anti-Graft and Corrupt Practices Act), R.A. No. 992 and R.A. No. 733 filed with the Tanodbayan.
- Preventive Suspension and Institutional Conversion
- On October 22, 1976, petitioner was preventively suspended pursuant to R.A. No. 3019, § 13; Dr. Pablo T. Mateo, Jr. was designated Officer-in-Charge and later Acting President.
- Presidential Decree No. 1341 (April 1, 1978) converted PCC into the Polytechnic University of the Philippines (PUP), expanding its objectives, structure and curricular offerings; Mateo became Acting President (April 3, 1979) and then President for six years (March 28, 1980).
- Acquittal, Reinstatement Orders and Conflicting Claims
- On July 11, 1980, the Circuit Criminal Court of Manila acquitted petitioner of graft charges and ordered his reinstatement as PUP President with back salaries and benefits during suspension.
- Administrative and Tanodbayan cases were dismissed in 1991 for mootness and failure to prosecute.
- Petitioner filed a motion for execution on February 12, 1992; the RTC issued writs of execution on March 6 and April 24, 1992 ordering reinstatement and back pay.
- Meanwhile, President Corazon C. Aquino appointed Dr. Jaime Gellor Acting President on March 26, 1992; the Court of Appeals issued a TRO on June 25, 1992 and, on July 15, 1992, set aside the reinstatement orders insofar as they covered post-conversion salaries.
Issues:
- Did P.D. No. 1341 abolish the PCC and thereby terminate petitioner’s right to reinstatement under the 1980 acquittal?
- Did P.D. No. 1437 (June 10, 1978) fixing six-year terms for state college and university presidents extinguish petitioner’s term on March 28, 1980 and limit his entitlement to separation pay rather than reinstatement and back salaries?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)