G.R. No. L-1273 - Singson vs. Quintillan

On November 21, 1937, the President of the Philippines appointed Jose F. Singson as ad interim judge of peace for the combined municipalities of Santo Domingo and San Ildefonso, Ilocos Sur.
The Commission on Appointments of the National Assembly confirmed his appointment on May 10, 1938.
Singson immediately took possession of his office and served continuously until the Japanese occupation of the province on December 10, 1941.

During the period of Japanese occupation, Singson was reassigned and served as judge of peace for the municipalities of Bantay, Caoayan, Santa Catalina, and San Vicente, still within the same province.
He did not contest that he had not originally requested the appointment, which may have been triggered by a pre-existing list in the Department of Justice’s archives.

Following the liberation and the reoccupancy of Ilocos Sur by American and Filipino forces, a military government was established, which designated Singson as judge of peace for Santo Domingo and San Ildefonso from April 1 until July 31, 1945.
With the reestablishment of the Commonwealth government on August 1, 1945, Singson received a new designation from Mauro Verzosa, the special delegate of the President, thereby ensuring that his service as judge of peace revived without a single day’s interruption.

On February 9, 1946, President Sergio Osmeña issued an ad interim appointment in favor of Singson for the same judicial post.
With the change in administration, President Osmeña was succeeded by President Manuel Roxas, who, on May 25, 1946, forwarded Singson’s nomination along with other matters to the Commission on Appointments.
The Commission disapproved Singson’s nomination on July 9, 1946.

On December 5, 1946, President Osmeña issued an ad interim appointment naming Vicente Quintillan as judge of peace for Santo Domingo and San Ildefonso.
Singson, contesting this appointment, refused to vacate his office and declined to surrender his files, registry books, and other judicial paraphernalia.
In response, Quintillan filed a complaint with Judge Ceferino de los Santos, the Judge of First Instance of Ilocos Sur, who then issued administrative Order No. 37 to effect the turnover of the office from Singson to Quintillan.

A declaration recognizing him as the legitimate judge of peace for Santo Domingo and San Ildefonso.
A declaration that Quintillan was guilty of illegal usurpation of the office and should be permanently removed from it.
A declaration nullifying the administrative order that attempted to dislodge him.
The issuance of an interdict preventing further attempts by Quintillan to evict him from his position.

The dispute centered on determining who had the legitimate right to occupy the office of judge of peace.

Whether Jose F. Singson, who had served continuously—from his initial appointment before the war, through the Japanese occupation, and after liberation—retained the right to be recognized as the judge of peace for Santo Domingo and San Ildefonso.
Whether the subsequent ad interim appointment given to Quintillan could override or bar Singson’s claim.

Whether Singson’s service during the Japanese occupation constituted an abandonment of his pre-war appointment under the Commonwealth.
Whether the transition through multiple designations (military government, special presidential delegate, etc.) affected the continuity of Singson’s tenure.

Whether Singson’s acceptance of new designations and an ad interim appointment after liberation implied a tacit abandonment of his original judicial rights.
The legal consequences of the Commission on Appointments’ disapproval of the post-liberation nomination in contrast with Singson’s continuous service.