Title
Garcia vs. Commission on Audit
Case
G.R. No. 75025
Decision Date
Sep 14, 1993
Employee dismissed for dishonesty, later acquitted in criminal case, granted executive clemency. Supreme Court ruled he is entitled to full back wages due to proven innocence and wrongful dismissal.

Case Digest (G.R. No. 199199)
Expanded Legal Reasoning Model

Facts:

  • Parties and administrative dismissal
    • Vicente Garcia, Supervising Lineman, Bureau of Telecommunications, Region IV (Lucena City).
    • Summarily dismissed on April 1, 1975 for dishonesty (loss of telegraph poles) via Adm. Case No. 975.
  • Criminal acquittal and clemency
    • Criminal case for qualified theft filed on same facts; acquitted January 23, 1980 by Court of First Instance.
    • Reinstatement request denied April 7, 1980; executive clemency granted August 26, 1981 by Resolution No. O.P. 1800.
  • Back wages claim and COA proceedings
    • Claim filed with COA for back salaries from April 1, 1975; denied October 12, 1982 (clemency silent on pay, no reinstatement).
    • Reinstated March 12, 1984 (records silent on position); new claim denied July 23, 1985 (no service, no pay).
  • Administrative appeal and SC petition
    • Appeal to the Office of the President denied April 21, 1986 (SC proper forum under Const. Art. IX-A, Sec. 7).
    • Petition for certiorari filed with SC; Solicitor General supports back wages; COA opposes (administrative liability, waiver, no service).

Issues:

  • Reinstatement by clemency
    • Whether executive clemency grounded on innocence effects automatic reinstatement.
  • Back wages entitlement
    • Whether petitioner is entitled to full back wages from April 1, 1975 to March 12, 1984.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.