Case Digest (G.R. No. L-12945)
Facts:
- The case Garchitorena v. Crescini, G.R. No. L-12945, was decided by the Supreme Court of the Philippines on February 16, 1918.
- Andres Garchitorena contested the election results for governor of Ambos Camarines against Manuel Crescini.
- The election occurred on June 6, 1916, with Crescini declared the winner on June 21, 1916.
- Garchitorena filed an election protest on July 1, 1916, in the Court of First Instance of Ambos Camarines.
- A decision was rendered on April 27, 1917, and communicated to the parties on April 30, 1917.
- Crescini argued that the judgment was null and void because the judge had accepted another office as Director of the Bureau of Lands on March 31, 1917, before the decision was filed.
- He claimed the judge had ceased to act in his judicial capacity as the successor had already qualified and commenced duties on March 28, 1917.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the judgment was null and void because the judge had ceased to hold office before issuing the decision.
- The Court annulled the lower court's decision and re...(Unlock)
Ratio:
- A judge who has vacated his office and accepted another position cannot render valid judgments.
- The Court emphasized that once a judge's term has ended and a successor is in place, any judgment issued by the former judge is void.
- There cannot be...continue reading
Case Digest (G.R. No. L-12945)
Facts:
The case of Garchitorena v. Crescini, G.R. No. L-12945, was decided by the Supreme Court of the Philippines on February 16, 1918. The petitioner-appellee, Andres Garchitorena, contested the election results for the office of governor of the Province of Ambos Camarines against the respondent-appellant, Manuel Crescini. The election occurred on June 6, 1916, and after the votes were canvassed, Crescini was declared the winner by the provincial board of canvassers on June 21, 1916. Following this, Garchitorena filed an election protest on July 1, 1916, in the Court of First Instance of Ambos Camarines. The trial proceeded, and a decision was rendered on April 27, 1917, which was communicated to the parties on April 30, 1917. However, Crescini contended that the judgment was null and void because the judge who issued it had accepted another office as the Director of the Bureau of Lands on March 31, 1917, prior to the decision being filed. He argued that the judge had ceased to act in his judicial capacity before the ruling was made, as the judge's successor had already qualified and commenced d...