People v. Domalaon
REITERATIONFacts
The Antecedents: Informations were filed against Silvestre Domalaon for violation of Republic Act No. 145. Hearings were conducted before Judge Anatolio Mañalac, who reserved his decisions. Judge Mañalac went on terminal leave but was authorized to decide cases he had tried in Sorsogon while in Manila. Judge Mañalac applied for retirement effective September 13, 1954. On June 21, 1954, Judge Genaro Tan Torres was appointed ad interim Judge of the 10th Judicial District, to preside over the Court of First Instance of Sorsogon. Judge Tan Torres qualified and assumed office on July 1, 1954. Procedural History: On July 1, 1954, Judge Mañalac deposited in the Manila Post Office an envelope containing his drafted judgments, addressed to the Clerk of Court of Sorsogon. The envelope was received in Sorsogon on July 3, 1954, and the judgments, dated June 12, 1954, were promulgated on the same date. The accused appealed. The Petition: The People of the Philippines sought a review of the Court of Appeals' resolution annulling the decisions, on the ground that they were promulgated on July 3, 1954, when Judge Mañalac no longer presided over the district, having been succeeded by Judge Tan Torres on July 1, 1954. The appellate court found the decisions invalid.
Issue(s)
Whether the promulgation of Judge Mañalac's decisions on July 3, 1954, was valid despite his having been succeeded by Judge Tan Torres on July 1, 1954. Whether the mailing of the decisions by Judge Mañalac on July 1, 1954, constituted valid promulgation.
Ruling
The Supreme Court affirmed the resolution of the Court of Appeals, holding that the decisions promulgated on July 3, 1954, were invalid. The cases were returned to the Court of First Instance of Sorsogon for adjudication based on the evidence already presented.
Ratio Decidendi
On the validity of the promulgation: The Court held that the promulgation of Judge Mañalac's decisions on July 3, 1954, was invalid because Judge Genaro Tan Torres had already qualified and assumed office as the judge of the Court of First Instance of Sorsogon on July 1, 1954. A judge's authority to decide cases ceases upon the qualification of his successor. Therefore, any decision rendered and promulgated after the successor has taken office is without binding effect. On whether mailing constituted promulgation: The Court rejected the argument that mailing the decisions on July 1, 1954, constituted promulgation. Promulgation, as defined by law and jurisprudence, involves the delivery of the decision to the clerk of court for filing and entry into the criminal docket. According to Section 9 of Rule 124, a decision is filed in court as of the day it is received by the clerk. In this case, the decisions were received by the clerk of court on July 3, 1954. Furthermore, in criminal proceedings, promulgation requires the reading of the judgment in the presence of the defendant and the judge, or by the clerk of court if the judge is absent, after the defendant or his attorney has been notified. Mailing the decision to the clerk of court does not satisfy these requirements for promulgation. The doctrine in Rodriguez vs. Commission on Election concerning promulgation of judgments of the Supreme Court, which involves a different procedure, was distinguished from the present case involving a Court of First Instance decision.
Main Doctrine
A judgment is considered promulgated when it is received by the clerk of court for filing and entry into the docket. If the judge who signed the decision is no longer presiding over the court at the time of promulgation, the decision has no binding effect.