Case Digest (G.R. No. L-48817)
Facts:
The case involves the People of the Philippines as the petitioner-appellant and Gregorio Malco as the respondent-appellee. The events leading to this case began with an Information filed on May 25, 1976, charging Malco with attempted rape in the Court of First Instance of Quezon, specifically in Crim. Case No. 463-G, which was assigned to Branch X presided over by Judge Mapalad A. Nanadiego. After the defense presented its case, the matter was submitted for decision on October 15, 1977. However, Judge Nanadiego retired on April 17, 1978, without rendering a decision. Subsequently, Judge Juan B. Montecillo was designated pro tempore to handle Branch X, and he decided the case on May 22, 1978. On June 9, 1978, Judge Conrado R. Antona was appointed as the permanent Presiding Judge of Branch X, taking his oath the following day, which effectively ended Judge Montecillo's temporary assignment. Despite this, on June 20, 1978, the Special Deputy Clerk of Court, Mateo M. Cabangon...
Case Digest (G.R. No. L-48817)
Facts:
Case Background:
- Gregorio Malco was charged with attempted rape in Crim. Case No. 463-G before the Court of First Instance of Quezon, Branch X, presided by Judge Mapalad A. Nanadiego.
- The case was submitted for decision on 15 October 1977 after the defense rested.
Judicial Transitions:
- Judge Nanadiego retired on 17 April 1978 without deciding the case.
- Judge Juan B. Montecillo, Presiding Judge of Branch III, was designated pro tempore to take over Branch X.
- Judge Montecillo decided the case on 22 May 1978.
Appointment of New Judge:
- On 9 June 1978, Judge Conrado R. Antona was appointed as the permanent Presiding Judge of Branch X. He assumed office on 10 June 1978, terminating Judge Montecillo’s temporary designation.
Promulgation of Decision:
- On 20 June 1978, Special Deputy Clerk of Court Mateo M. Cabangon promulgated Judge Montecillo’s decision acquitting Gregorio Malco.
Prosecution’s Motion:
- On 30 June 1978, Special Counsel Hjalmar P. Quintana moved to set aside the judgment of acquittal, arguing that Judge Montecillo no longer had authority to decide the case.
- Judge Antona denied the motion on 10 July 1978, stating that the trial court could not review the decision of a co-equal court.
Petition to Supreme Court:
- The Provincial Fiscal, with authority from the Solicitor General, filed a petition arguing that Judge Montecillo’s decision was null and void since he was no longer the judge-designate of Branch X when the decision was promulgated.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Authority of Detailed Judges:
- A judge whose temporary detail to a vacant branch has expired remains an incumbent judge of the branch where he is permanently assigned. He may still decide cases submitted to him during his temporary detail, even after the vacancy has been filled.
Jurisdiction of the Court:
- Jurisdiction is vested in the court, not in the judges. Each branch of the Court of First Instance (now Regional Trial Court) is not a separate court. Thus, a judge from one branch may decide cases submitted to him during his temporary detail in another branch.
Validity of Judge Montecillo’s Decision:
- Judge Montecillo penned the decision on 22 May 1978 while his temporary designation at Branch X expired on 10 June 1978. He was still an incumbent judge of Branch III at the time of promulgation, giving him authority to decide the case.
No Evidence of Bad Faith:
- There was no evidence of bad faith on the part of Judge Montecillo or the Special Deputy Clerk of Court in preparing and promulgating the decision.
Double Jeopardy:
- The Court emphasized that technicalities should not be used to annul a judgment of acquittal, as it would violate the principle of double jeopardy.
Precedent and Caution:
- The case should not be taken as a precedent for judges to continue exercising authority over courts where there are already incumbent judges, except under similar circumstances. Judges on temporary detail must ensure they have authority over cases they decide.