It's a weird situation because if a facebook engineer reset his password to something else, he'd never be able to get out of jail? Seems odd to make a criminal court order based on a commercial authentication scheme.
If he forgets the password or it gets magically reset somehow and he legitimately no longer has access to the account (a stretch....password resets are a thing for this reason), then perhaps he should still serve his time anyway as the crime has already been committed. If it was unrecoverable, then of course he'd still be able to get out. It even says in the article he was sentenced to 14 months, not until he gave up the password.