Bueno Industrial & Development Corp. v. Enage
REITERATIONFacts
The Antecedents: R.C. Aquino Timber & Plywood Co., Inc. (RCA TIMPLY) filed a case (Special Civil Case No. 168) against Bueno Industrial & Development Corporation (BIDCOR) in the Court of First Instance (CFI) of Agusan. BIDCOR filed an amended answer with counter-claims. The CFI conducted hearings on a preliminary injunction, and the evidence presented was agreed upon by the parties to form part of the evidence on the merits. The CFI granted the preliminary injunction, which was later nullified by the Supreme Court in G.R. No. L-23183, practically adjudicating the merits of RCA TIMPLY's claims. Procedural History: The CFI issued a Pre-Trial Order and later an order for the assessment of damages for BIDCOR's counter-claims. Respondent Judge Enage took cognizance of the case. He issued a restraining order to enforce the Supreme Court's decision in G.R. No. L-23183 and set the continuation of the hearing. Subsequently, the province of Agusan was divided into Agusan del Norte and Agusan del Sur by Republic Act No. 4979, and the CFI of Agusan del Sur was created by Republic Act No. 6092. On February 13, 1970, Judge Enage issued an order transferring Civil Case No. 168 to the CFI Judge of Agusan del Sur, stating he no longer had jurisdiction. This was contrary to the opinion of the Undersecretary of Justice, who advised that Judge Enage retained jurisdiction over cases filed before the creation of the Agusan del Sur court. The Petition: BIDCOR filed a petition for certiorari and mandamus, praying for the reversal of Judge Enage's order transferring the case. BIDCOR argued that jurisdiction, once acquired, is retained. Despite a motion for reconsideration, Judge Enage refused to change his stand, citing the need for the Supreme Court to settle the question of jurisdiction between two different branches of two different CFIs from two different provinces. Respondents failed to file an answer or memorandum.
Issue(s)
Whether the Court of First Instance of Agusan del Norte, Branch II, presided over by respondent Judge Enage, retained jurisdiction over Civil Case No. 168 despite the division of the province of Agusan and the creation of the Court of First Instance of Agusan del Sur. Whether respondent Judge Enage committed a grave abuse of discretion in transferring the case to the Court of First Instance of Agusan del Sur.
Ruling
The petition is granted. The Court of First Instance of Agusan del Norte, Branch II, is ordered to proceed with the hearing of Civil Case No. 168 until its complete termination. The impugned orders of respondent judge transferring the case are set aside.
Ratio Decidendi
On the issue of jurisdiction (Issue 1): The Supreme Court reiterated the well-entrenched rule that jurisdiction once acquired by a court over a case remains with it until the proceedings are finally terminated, unless there is a statute that expressly prohibits the continuance of the exercise thereof. The division of the province of Agusan into Agusan del Norte and Agusan del Sur, and the creation of the Court of First Instance of Agusan del Sur, did not automatically divest the original court of its jurisdiction over cases filed prior to such division. The Court emphasized that the relevant Republic Acts did not provide for any contingency that would transfer jurisdiction over pre-existing cases. The Court noted that the Secretary of Justice had twice advised respondent court to continue exercising jurisdiction, first through an administrative order transferring the case to Branch II and later by wire stating that the court retained jurisdiction over cases filed before the creation of the Agusan del Sur court. The Court found it unusual for the respondent judge to question his jurisdiction after these administrative advisories. The Court also highlighted the extensive proceedings already held in the case, including hearings on preliminary injunction, presentation of evidence on the merits, and pre-trial, all of which would be rendered moot by a transfer of jurisdiction, causing great inconvenience and complications to the parties. The Court stressed that once jurisdiction attaches properly to a court, that court has the legal authority and duty to proceed to the end. The failure of the respondents to refute the petitioner's arguments further supported the petitioner's position. Therefore, the Court concluded that Judge Enage should have continued with the case. On the issue of grave abuse of discretion (Issue 2): The Supreme Court's reasoning regarding the retention of jurisdiction directly implies that Judge Enage's transfer of the case constituted a grave abuse of discretion. By disregarding the established principle of continued jurisdiction, the advisories from the Secretary of Justice, and the advanced stage of the proceedings, the judge acted outside the bounds of his authority. The transfer would render prior proceedings moot and cause undue hardship to the parties, further demonstrating the abuse of discretion.
Main Doctrine
Jurisdiction once acquired by a court over a case remains with it until the proceedings are finally terminated, unless there is a statute that expressly prohibits the continuance of the exercise thereof. Administrative directives from the Secretary of Justice regarding the transfer of cases should be heeded.