Un Pak Leung v. Nigorra
REITERATIONFacts
The Antecedents: On March 31, 1905, the justice of the peace of Manila rendered judgment against the defendants and in favor of the plaintiff. The defendants appealed to the Court of First Instance. Procedural History: On September 2, 1905, the Court of First Instance affirmed the decision of the justice of the peace. The defendants appealed to the Supreme Court. The Petition: The plaintiff filed a motion for rehearing, contending that the Supreme Court lacked jurisdiction to decide the cause because Section 16 of Act No. 1627 deprived the court of jurisdiction in cases originally commenced in the court of the justice of the peace. This section provided that judgments rendered by the Court of First Instance on appeal from the justice of the peace shall be final and conclusive, except in cases involving the validity or constitutionality of a statute or municipal ordinance.
Issue(s)
Whether Section 16 of Act No. 1627, by making CFI judgments on appeal from the Justice of the Peace final and conclusive, deprived the Supreme Court of jurisdiction over an appeal that was perfected and pending before the Act's effective date.
Ruling
The motion for rehearing is denied. The Supreme Court retains jurisdiction over the case.
Ratio Decidendi
On Issue 1: The Supreme Court held that it retained jurisdiction over the cause despite the enactment of Act No. 1627. The Court reasoned that the appeal in the present case was made and perfected nearly a year and a half before the said Act went into effect on July 1, 1907. While it is a settled doctrine that the repeal of an act giving jurisdiction is generally an express prohibition of the exercise of that jurisdiction, the Court found that it was not the intention of the Philippine Commission to deprive persons of the right to have their already perfected appeals considered. The Court distinguished the present case from Ex parte McCardle (74 U.S. 506) and Railroad Company v. Grant (98 U.S. 398), noting that in those instances, the amended laws contained express language that specifically deprived the higher court of jurisdiction over pending cases or provided that cases "may [not] be reexamined." In contrast, Act No. 1627 merely stated that judgments "shall be final and conclusive," which the Court interpreted as applying prospectively to judgments rendered after the law's inception, rather than divesting jurisdiction already acquired over perfected appeals. Consequently, the Supreme Court concluded that Act No. 1627 did not manifest a sufficiently clear intent to disrupt the status of cases already submitted to it before the law’s operation.
Main Doctrine
An appeal perfected prior to the effectivity of a new law divesting appellate jurisdiction is not affected by the new law, as the legislature is presumed not to intend the deprivation of vested rights.