G.R. No. L-30772 - Philippine National Railways vs. Domingo

Philippine National Railways (PNR) initiated the case by seeking certiorari and prohibition.
The petition raises the legal issue whether a trial court in a criminal case has jurisdiction to modify its judgment to include non-criminal remedies.

Respondent Juan Mafe, a mechanic employed by PNR, was charged in an information for qualified theft.
The charge pertained to the alleged theft of one brass bearing valued at P45.00 from his employer’s shop.
Evidence presented in the criminal case included:

Testimony of the Railways’ policeman who apprehended Mafe in street clothes with a traveling bag containing the brass bearing.
Testimony of a Manila Police Department patrolman who recorded Mafe’s extrajudicial confession.
Corroborative testimony of a Railways’ security guard involved in the apprehension.
Physical evidence, namely the bag, the brass bearing, and a signed extrajudicial confession.

Mafe denied criminal intent, asserting that he was in the process of returning the brass bearing.
He repudiated his previously recorded extrajudicial confession, claiming it was made under coercion and without being allowed to review its contents.

The trial court rendered a decision on January 18, 1969, acquitting Mafe on the ground that the prosecution failed to prove his guilt beyond reasonable doubt.
After the acquittal was promulgated on February 7, 1969, Mafe filed a motion on February 19, 1969, seeking an amendment of the decision.
The motion alleged that he had been dismissed from service on July 4, 1967 “with prejudice to reinstatement” by resolution of the Railways’ board of directors dated January 19, 1968.
Mafe prayed that the decision be amended to order his reinstatement along with payment of back salaries and restoration of accrued benefits and privileges.

On March 3, 1969, the trial court set a hearing for the motion and notified the parties, including the general manager of PNR.
On March 27, 1969, the trial court issued an “amendatory decision” adding a paragraph to its original judgment, ordering the immediate reinstatement of Mafe, full payment of his salary from July 4, 1967 until reinstatement, and the restoration of all accrued employee rights.

PNR, as petitioner, contested the trial court’s amendatory decision on the ground that it lacked jurisdiction over matters pertaining to administrative remedies such as reinstatement and back salaries.
On August 27, 1969, the Court issued a writ of preliminary injunction stopping the enforcement of the amendatory decision pending further resolution of the issue.

Whether the trial court in a criminal case, having rendered a judgment of acquittal, has the authority to modify its decision to include administrative remedies such as reinstatement and payment of back salaries.
Whether the amendment of the acquittal by ordering non-criminal relief (reinstatement and back wages) is within the court’s jurisdiction.

Whether the rights to reinstatement and salary recovery, if any, arise as a part of the criminal proceeding or are issues that must be separately pursued in proper administrative or civil actions.
Whether the trial court overstepped by incorporating relief that usually falls under administrative jurisdiction after the finality of the acquittal.