ABC Davao Auto Supply, Inc. v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Petitioner ABC Davao Auto Supply, Inc. filed a complaint for a sum of money, attorney's fees, and damages against respondent Abundio T. Merced, doing business as Southern Engineering Works. The case originated in the Court of First Instance of Davao City, Branch XVI. 2. Procedural History: The case involved multiple judges due to judicial reorganization. Pre-trial was conducted by Judges Canizares-Nye, Siazon, and Dinopol. Evidence was heard by Judge Fuentes and later by Judge Agton. Judge Agton rendered a decision in favor of the petitioner on June 9, 1987. Private respondent moved for reconsideration, which was denied by Judge Marasigan on March 1, 1988. The Court of Appeals (CA) nullified Judge Agton's decision, ruling he was neither the de jure nor de facto judge of Branch XVI at the time of the decision, and remanded the case. 3. The Petition: Petitioner seeks review of the CA's decision, raising the sole issue of the validity of Judge Agton's decision. The petition argues that the case was submitted for decision in March 1987 when Judge Marasigan was presiding, but Judge Agton rendered the decision. However, it contends that Judge Marasigan's subsequent action on the motion for reconsideration cured any defect, adopting Judge Agton's decision. The petition also asserts that jurisdiction attaches to the court, not the judge, and Judge Agton, as an incumbent judge of the same court, albeit in a different branch, could validly promulgate the decision, especially since the CA's ruling would unduly prolong the litigation.
Issue(s)
Whether the decision rendered by Judge Agton is valid despite his transfer to another branch before the promulgation of the decision. Whether the subsequent actions of Judge Marasigan cured any defect in Judge Agton's decision, considering the judicial reorganization and the principle of continuous jurisdiction.
Ruling
The Supreme Court set aside the decision of the Court of Appeals and reinstated the decision of Judge Agton.
Ratio Decidendi
On the validity of Judge Agton's decision: The Court held that a case is deemed submitted for decision upon the filing of the last pleading. In this case, the records showed the case was submitted for decision in March 1987, when Judge Marasigan was already presiding over Branch XVI. Therefore, the case was submitted to Judge Marasigan, not Judge Agton. However, the Court noted that Judge Agton's decision was subsequently acted upon by Judge Marasigan, who denied the motion for reconsideration. This action by Judge Marasigan indicated that he subscribed to and adopted Judge Agton's decision in toto, thereby curing any incipient defect. The presumption that both magistrates regularly performed their official functions was not rebutted. On the effect of judicial reorganization and jurisdiction, and whether Judge Marasigan's actions cured any defect: The Court clarified that for a judgment to be binding, it must be signed and promulgated during the incumbency of the judge whose signature appears thereon. This is in line with the resolution implementing B.P. 129, which requires the judge to be an incumbent judge of the same court, even if assigned to a different branch, at the time of promulgation. The Court emphasized that branches of the trial court are not distinct tribunals, and jurisdiction attaches to the court, not the judge. Therefore, Judge Agton could not have lost jurisdiction over the case simply because he was transferred to another branch within the same judicial region. The continuity of a court and its proceedings are not affected by the transfer or cessation from service of a judge. Remanding the case would only prolong the litigation and contradict the policy of speedy disposition of cases.
Main Doctrine
A decision rendered by a judge who was transferred to another branch but whose decision was subsequently adopted and affirmed in toto by the incumbent judge, who also acted on the motion for reconsideration, is considered valid, as any incipient defect is cured and the presumption of regularity in the performance of official functions prevails. Jurisdiction attaches to the court, not the judge.