Facts:

• Benjamin Z. Yelo, a suspended member of the Bacolod City police force, faced charges of slight physical injuries.
• The city attorney filed the information against him on March 25, 1947.
• Yelo was found guilty and sentenced to pay a fine of P25 plus costs.
• He appealed to the Court of First Instance of Negros Occidental, which reviewed the case and reproduced the original information.
• On December 23, 1947, the Court of First Instance dismissed the case due to the absence of the prosecution and the complainant.
• Yelo's attorney claimed that under Article 2272 of the Revised Administrative Code, Yelo was entitled to his salary during suspension.
• The court initially agreed but later modified its order, removing the provision for back compensation after a motion for reconsideration by the city attorney.
• Yelo argued that the court lacked jurisdiction to modify the order after the case dismissal.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed the Court of First Instance's order, stating the court retained jurisdiction to modify the payment of back compensation within fifteen days of notifying the defendant.
• The judgment on back compensation was deemed within the court's discretion and did not violate the ...(Unlock)

Ratio:

• The Supreme Court held that the Court of First Instance had the authority to revise its orders before the appeal period expired.
• Citing "United States vs. Vayson," the court emphasized that courts can correct or change judgments prior to fina...continue reading