Comia v. Nicolas
REITERATIONFacts
The Antecedents: Estanislao Garachico and fourteen other former members of the Naujan police force filed a petition for mandamus, quo warranto, prohibition, and damages against Mayor Porfirio Comia and the policemen who replaced them. They sought reinstatement and unpaid salaries from January 1, 1960. Procedural History: The case was heard by Judge Juan de Borja, whose temporary assignment expired before he could render a decision. Judge Andres Sta. Maria took over, and after several hearings and motions concerning the status of a supposed decision by Judge de Borja, including the submission of an unsigned copy, the case was considered submitted for decision on January 9, 1964. Judge Sta. Maria was transferred, and Judge Nicanor P. Nicolas assumed office. On September 8, 1964, Judge Nicolas rendered a decision, amended on September 9, 1964, declaring the termination of most petitioners invalid and ordering the reinstatement of Estanislao Garachico with back salaries. The respondents filed a motion to set aside this judgment, alleging that Judge de Borja had already decided the case on February 13, 1962. The motion was denied. Motions for execution were filed and granted, leading to writs of execution and levy on municipal properties. The Court of Appeals dismissed a petition for certiorari filed by Mayor Manuel Marcos. The respondents filed another motion to stay execution, which was also denied. Subsequently, Porfirio Comia and Chief of Police Antonio Gaba, Sr. filed the instant petition for certiorari and prohibition. The Petition: Petitioners Porfirio Comia and Chief of Police Antonio S. Gaba, Sr. filed an original petition for certiorari and/or prohibition with mandatory preliminary injunction. They contend that the decision rendered by Judge Nicanor P. Nicolas on September 8, 1964, as amended by the order of September 9, 1964, and subsequent orders in Civil Case No. R-979, are null and void. Their principal argument is that the case had already been decided by Judge Juan de Borja on February 13, 1962, which decision had become final, thus divesting Judge Nicolas of jurisdiction to render a subsequent decision.
Issue(s)
Whether the decision rendered by Judge Nicanor P. Nicolas on September 8, 1964, as amended, is null and void. Whether Judge de Borja's decision dated February 13, 1962, was validly rendered and filed, thereby divesting the respondent judge of jurisdiction.
Ruling
The Supreme Court declared the decision dated September 8, 1964, as amended by the order dated September 9, 1964, and all other orders of the respondent judge in Civil Case No. R-979, null and void. The preliminary injunction enjoining the respondents from enforcing said decision and orders was made permanent. The Court found that Judge de Borja's decision was validly rendered and filed, making the subsequent decision by Judge Nicolas void.
Ratio Decidendi
On Issue 1: The Supreme Court held that the decision rendered by Judge Nicanor P. Nicolas on September 8, 1964, as amended by the order of September 9, 1964, is null and void. This is because the case had already been validly decided by Judge Juan de Borja on February 13, 1962. The subsequent decision by Judge Nicolas was issued after the first decision had become final and executory, meaning the court a quo had lost jurisdiction over the case. A void judgment is considered to have no legal effect and cannot divest rights or be the basis for any legal action. On Issue 2: The Court found that Judge de Borja's decision dated February 13, 1962, was validly rendered and filed. Evidence, including the deposition of Judge de Borja and the monthly reports of the Clerk of Court, established that the decision was penned by Judge de Borja and sent to the Clerk of Court of Oriental Mindoro via Philippine Air Lines, where it was received by the Clerk of Court, Cristino Paras, on February 17, 1962. The filing of the judgment with the Clerk of Court constitutes its rendition. Furthermore, proof of service of copies of this decision to the respective attorneys of the parties was also established through registry receipts and certifications from the postmaster. Since no appeal or motion for reconsideration was filed within the reglementary period from the service of this decision, it became final and executory, divesting the respondent judge of jurisdiction to render a new decision.
Main Doctrine
The Supreme Court reiterated that a judgment is rendered upon its filing with the Clerk of Court. Even if the judge who heard the case signs it outside the province due to a temporary assignment, it is considered filed as of the date of its receipt by the Clerk of Court. Consequently, any subsequent decision rendered by another judge on the same case, after the first decision has become final and executory, is considered null and void for having been issued without jurisdiction. This principle underscores the finality of judgments once they are properly filed and served.