G.R. No. 183034 - Spouses Santos vs. Alcazar

The parties involved are the People of the Philippines (plaintiff and appellee) and Eligio Legaspi et al. (defendants and appellants).
The case arose from an incident involving members of the municipal police force of Naga, Camarines Sur who were charged with robbery.
The suspects – Eligio Legaspi, Dionisio Perez, Leon Marano, Andres Concha, Andres Quintano, Antonio Borromeo, Isidoro Agaton, and Mariano Oiiate – held various positions (chief, sergeant, and members) within the municipal police.

On October 21, 1936, the accused were charged in the Court of First Instance of Camarines Sur (criminal case No. 8980).
Pursuant to section 2272 of the Revised Administrative Code of 1917, amended by Act No. 3206, the municipal president of Naga suspended the accused effective October 1, 1936, pending the resolution of the case.
The suspension was deemed necessary because the accused were facing criminal charges for robbery, which triggered the statutory provision for immediate suspension of municipal police officials.

Upon hearing the case, the trial court ultimately absolved the accused on the basis of reasonable doubt.
Importantly, the decision did not contain any pronouncement regarding the accused’s right to claim their salaries for the period of suspension.
On September 17, 1937, the appellants filed a motion requesting the trial court to confirm their entitlement to receive the salaries they lost during the suspension.
The trial court, by its order dated October 13, 1937, denied the petition for salary payment.

The case prominently features the interpretation of section 2272 of Act No. 2711, as amended by Act No. 3206.
The statute mandates that if a chief or member of the municipal police is accused in court of any felony or violation of law, they shall be suspended pending the case’s final decision.
Additionally, in the event of an acquittal, the accused may be entitled to payment of the entire salary they missed during the suspension—but only if “the court should provide in its sentence.”
The wording clearly implies that mere exculpation does not automatically trigger salary payment; a specific court pronouncement is required.

The primary legal issue is whether the trial court erred by refusing to include a pronouncement in its decision on the appellants’ right to receive their salaries for the period of suspension.

Does an acquittal automatically entitle a suspended police official to receive the unpaid salary during suspension?
Is the omission of a salary-claim pronouncement in the acquittal order a reversible error given the statutory requirement that the court must “provide in its sentence” for such payment?