Facts:

The case involves ABC Davao Auto Supply, Inc. as the petitioner and the Court of Appeals along with Abundio T. Merced, doing business as Southern Engineering Works, as the respondents. The events leading to this case began on October 6, 1980, when ABC Davao Auto Supply, Inc. filed a complaint for a sum of money, attorney's fees, and damages against Merced in the Court of First Instance (now known as the Regional Trial Court) of Davao City, specifically assigned to Branch XVI. The pre-trial was initially conducted by Judge Pacita Canizares-Nye and subsequently by Judges Alejandro Siazon and Cristeto Dinopol. The trial commenced on November 20, 1984, under Judge Renato Fuentes, who heard the evidence from both parties. However, the cross-examination of the private respondent took place on August 28, 1985, and the rebuttal and sur-rebuttal evidence were presented before Judge Roque Agton, who had assumed office on August 1, 1985. Following a reorganization of the judiciary u...

Facts:

Background of the Case

• On October 6, 1980, petitioner ABC Davao Auto Supply, Inc. filed a complaint for a sum of money, attorney’s fees, and damages against private respondent Abundio T. Merced, doing business as Southern Engineering Works, before the Court of First Instance (now Regional Trial Court) of Davao City, Branch XVI.
• The case involved unpaid vehicular parts purchased by Merced from ABC Davao Auto Supply, Inc. on credit, with an outstanding balance of P99,217.15. Merced refused payment, claiming the accounts had not yet matured.

Judicial Proceedings

• The pre-trial was conducted by Judge Pacita Canizares-Nye, followed by Judges Alejandro Siazon and Cristeto Dinopol.
• Trial commenced on November 20, 1984, with Judge Renato Fuentes presiding. Judge Roque Agton took over on August 1, 1985, and heard the cross-examination of Merced on August 28, 1985, as well as the rebuttal and sur-rebuttal evidence.
• After the judicial reorganization under the Aquino administration, Judge Agton was transferred to another branch within the same Judicial Region. Judge Romeo Marasigan assumed office in Branch XVI on February 3, 1987.
• In May 1987, Judge Marasigan acted on Merced’s motion for an extension of time to file a memorandum. However, on June 9, 1987, Judge Agton, who was no longer assigned to Branch XVI, rendered a decision in favor of ABC Davao Auto Supply, Inc.
• Merced filed a motion for reconsideration, which was denied by Judge Marasigan on March 1, 1988. Merced then appealed to the Court of Appeals (CA).

Court of Appeals Decision

• The CA nullified Judge Agton’s decision, ruling that he was neither the judge de jure nor the judge de facto of Branch XVI at the time he rendered the judgment. The case was remanded to the lower court.

Issue:

1. Whether Judge Agton’s decision is valid despite being rendered after his transfer to another branch.
2. Whether the case should be remanded to the lower court for a new decision.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)