People v. Peralta
REITERATIONFacts
The Antecedents: Criminal Cases Nos. 3692 and 3965 were filed in the Court of First Instance of Ilocos Sur for double murder and double attempted murder, respectively, following the killing of Mayor Lorenzo Formoso, Sr., and another person, and the wounding of two others. The accused were Terio de Peralta, Lucio Fabillaran, and Johnny Fabillaran. These cases were initially assigned to Branch I, presided over by Judge Felix Antonio, who commenced hearing them. Procedural History: Upon the creation of Branch III and the appointment of Judge Angelino Salanga, the cases were raffled to his branch. Judge Salanga resumed hearing the cases after the prosecution had rested its case against one accused and was about to finish presenting evidence against the others. Subsequently, Judge Salanga was appointed to preside over the newly-created Branch IV at Candon, while Judge Deogracias Solis took over Branch III. Administrative Order No. 184 authorized Judge Salanga to continue holding court at Vigan to try and decide cases. When the cases were called before Judge Solis, he, upon being informed that Judge Salanga had partially heard them, ordered the postponement of the hearing and the return of the records to Judge Salanga's court (Branch I). Judge Salanga then set the cases for hearing, prompting the private prosecutors to question his authority and jurisdiction. Judge Salanga denied the motion, asserting his authority under Administrative Order No. 184. The private prosecutors filed a motion for postponement, which Judge Salanga granted to allow them to elevate the issue to the Supreme Court, while still maintaining his belief in his authority and setting new hearing dates. The Petition: Lourdes Itchon Vda. de Formoso, the widow of the late Mayor Lorenzo Formoso, Sr., and the People of the Philippines filed petitions for certiorari and prohibition with preliminary injunction, seeking to set aside the order of Judge Salanga and to enjoin him from hearing the cases, alleging he acted without or in excess of jurisdiction.
Issue(s)
Whether or not respondent Judge Angelino Salanga had authority and jurisdiction to continue hearing and to decide Criminal Cases Nos. 3692 and 3965 of the Court of First Instance of Ilocos Sur.
Ruling
The petitions for certiorari and prohibition are dismissed, and the restraining order issued by this Court is lifted. The Supreme Court held that respondent Judge Salanga had the authority to continue hearing and decide the cases.
Ratio Decidendi
On Issue 1: The Supreme Court held that jurisdiction is vested in the court, not in the judge. Citing Bacalso vs. Ramolete, the Court reiterated that the various branches of the Court of First Instance (CFI) are coordinate and co-equal courts, and jurisdiction over a case attaches to the CFI of the province as a whole, not exclusively to one judge or branch. Therefore, any branch of the CFI of Ilocos Sur had jurisdiction to try and decide Criminal Cases Nos. 3692 and 3965, and the initial assignment by raffle to Branch III did not grant that branch exclusive jurisdiction. The Rules of Court, specifically Section 7 of Rule 22, allows for the assignment or transfer of cases between branches, whether by raffle or upon accord among judges, provided the parties are given due notice. In this instance, when Judge Solis of Branch III transferred the cases to Branch I, presided over by Judge Salanga, the parties were present and had due notice, satisfying the procedural requirement, and the prosecution did not file any motion for reconsideration at that time. The transfer was deemed proper, considering Judge Salanga had already heard practically all the main evidence of the prosecution, making him best situated to continue. Furthermore, Administrative Order No. 184, issued by the Secretary of Justice pursuant to Section 56 of the Judiciary Act of 1948 (Republic Act No. 296), validly authorized Judge Salanga to hold court in Vigan and try and decide cases assigned or transferred to Branch I. The Court also dismissed insinuations of bias, affirming that prejudice is not presumed and that judges are expected to administer justice impartially. While the specific question regarding Judge Salanga's authority under Administrative Order No. 184 became moot due to his subsequent transfer to another judicial district, the Court nevertheless provided guidance. It pointed out that under the second paragraph of Section 51 of the Judiciary Act of 1948 and Section 9 of Rule 135 of the Rules of Court, a judge who has partially heard a case may be authorized by the Supreme Court to continue hearing and deciding it, notwithstanding his transfer or appointment to another court of equal jurisdiction, upon petition of any of the parties and recommendation of the respective district judge.
Main Doctrine
A judge may continue hearing and deciding a case even after transfer to another branch or station, provided there is proper notice to the parties and an administrative order authorizing such continuation, or if authorized by the Supreme Court upon petition and recommendation. The jurisdiction vests in the court, not the judge, and cases may be transferred between branches.