Case Digest (G.R. No. 113296)
Facts:
The case revolves around ABC Davao Auto Supply, Inc. (Petitioner) and the Court of Appeals and Abundio T. Merced, doing business as Southern Engineering Works (Respondents). The events began on October 6, 1980, when the Petitioner filed a complaint for a sum of money, attorney’s fees, and damages against the Respondents in the Court of First Instance of Davao City, which was raffled to Branch XVI. Initially, pre-trial hearings were conducted by Judge Pacita Canizares-Nye and later by Judges Alejandro Siazon and Cristeto Dinopol. The trial saw substantial actions and hearings, including the main evidentiary hearing held by Judge Renato Fuentes on November 20, 1984. Subsequently, the Respondent's cross-examination occurred on August 28, 1985, and further rebuttal and sur-rebuttal presentations were conducted by Judge Roque Agton, who had assumed roles previously held by the other judges.
However, following a judicial reorganization under the Aquino administration, Judge Agton
Case Digest (G.R. No. 113296)
Facts:
In October 1980, petitioner ABC Davao Auto Supply, Inc. filed a complaint for a sum of money, attorney’s fees, and damages before the Regional Trial Court (RTC) of Davao City. The case was initially handled in Branch XVI with pre-trial proceedings conducted by Judge Pacita Canizares-Nye and further developed by Judges Alejandro Siazon and Cristeto Dinopol. During trial, evidence was heard by Judge Renato Fuentes, after which Judge Roque Agton assumed office on August 1, 1985 and heard the latter stages of the litigation—including cross-examination of the private respondent and the introduction of rebuttal and sur-rebuttal evidence.However, due to the judiciary’s reorganization under the Aquino administration, Judge Agton was transferred to another branch, and Judge Romeo Marasigan, who took office on February 3, 1987, was assigned to Branch XVI. In May 1987, Judge Marasigan acted on a motion for an extension of time to file a memorandum by the private respondent. On June 9, 1987, Judge Agton rendered a decision in favor of petitioner. Subsequently, the private respondent sought reconsideration, but Judge Marasigan, then presiding, denied the motion on March 1, 1988. The private respondent subsequently appealed to the Court of Appeals (CA), which nullified Judge Agton’s decision on the ground that at the time of rendering it, Judge Agton was neither the judge de jure nor de facto of Branch XVI. The CA remanded the case to the lower court, thereby prompting the petition to question the validity of Judge Agton’s decision.
Issues:
The primary issue was whether the decision rendered by Judge Agton—issued after his transfer from RTC Branch XVI—remained valid. Specifically, the petition questioned if the submission and subsequent judgment were valid given that the case had been submitted for decision after the necessary pleadings were filed, and if the subsequent actions by Judge Marasigan (including acting on the motion for reconsideration) implied a continuation or repudiation of Judge Agton’s original decision.Ruling:
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Ratio:
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Doctrine:
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