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ISABELO T. CRISOSTOMO v. CA

## FACTS:

The petitioner, Isabelo Crisostomo, served as the President of the Philippine College of Commerce (PCC) until he was preventively suspended in 1976. In 1980, he was acquitted of the charges filed against him and ordered to be reinstated with entitlement to the salaries and benefits he failed to receive during his suspension. However, in 1992, a new acting president was appointed for the PCC, leading to a contempt citation and a petition filed by the People of the Philippines challenging Crisostomo's reinstatement.

The Court of Appeals set aside the orders and writs of reinstatement issued by the trial court. It disallowed the payment of salaries and benefits to Crisostomo after the conversion of PCC to the Polytechnic University of the Philippines (PUP), limiting the recovery to the period of his suspension until the conversion. The court explains that P.D. No. 1341 did not abolish the PCC but changed its name, curricular offerings, and structure, making the PUP a continuation of the PCC's existence. Therefore, Crisostomo's reinstatement as the PCC President is no longer possible due to the promulgation of P.D. No. 1437, which was issued subsequent to the conversion.

## ISSUES:

  1. Whether the conversion of the Philippine College of Commerce (PCC) into the Polytechnic University of the Philippines (PUP) through Presidential Decree No. 1341 effectively constitutes the abolition of the PCC or merely a renaming and expansion thereby allowing Isabelo T. Crisostomo to be reinstated as President.

  2. Whether Crisostomo is entitled to the payment of salaries and benefits lost during his suspension after the conversion of PCC to PUP, specifically accruing after the issuance of P.D. No. 1437 which established new terms for the presidency of state universities and colleges.

## RULING:

  1. The Supreme Court found that the conversion of PCC into PUP did not amount to abolishing the former but was merely a change in academic status, name, and organizational structure. This implies continuity rather than the establishment of a new entity.

  2. However, despite this finding, the Court ruled that reinstatement of Crisostomo as President of PUP and payment of benefits accruing after the conversion was not possible, as his term had effectively ended with the promulgation of P.D. No. 1437 which set new terms for incumbents. The Court stated that salaries and benefits should only be computed up to the end of his term, which terminated on March 28, 1980, when Dr. Pablo T. Mateo, Jr. was appointed as President of PUP.

## PRINCIPLES:

  1. Change vs. Abolition of an Institution: The mere expansion of curricular offerings and changes in organizational structure without explicit statutory language stating abolition imply continuity of the institution under a new name and expanded role rather than establishment of a new entity.

  2. Term of Office and Reinstatement: If a significant legal or organizational change occurs within a public institution (e.g., issuance of a new decree affecting terms or structure), prior positions held may effectively be considered terminated, thereby preventing reinstatement, unless explicit provision is made for such reinstatement.

  3. Entitlements upon Non-Reinstatement: If reinstatement is not feasible due to statutory changes affecting terms of office, affected individuals are generally entitled only to benefits accrued until the end of their lawful term.