Title
Tagal vs. Johnston
Case
G.R. No. 9767
Decision Date
Feb 5, 1915
Petitioner Francisca Tagal seeks a writ of mandamus against Judge C.D. Johnston, arguing that the judge lacked jurisdiction to rule on a motion for a new trial after delegating jurisdiction to a justice of the peace, but the court denies the petition, stating that the judge had the power and jurisdiction to resume control of the case.
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Case Digest (G.R. No. 9767)

Facts:

  • The case Tagal v. Johnston (G.R. No. 9767) was decided by the Supreme Court of the Philippines on February 5, 1915.
  • Petitioner Francisca Tagal sought a writ of mandamus against C.D. Johnston, the Judge of First Instance, and respondents Manuel Baricaua, Jacobo Tumacay, and Raymundo Gaffud.
  • The dispute originated in the justice of the peace court of Enrile, Cagayan, where Tagal aimed to recover possession of agricultural land and claim damages.
  • The justice of the peace ruled in favor of Tagal, prompting the defendants to appeal to the Court of First Instance.
  • Judge Johnston delegated the case to Ramon Valdez, a justice of the peace from Tuguegarao, due to his vacation.
  • Valdez issued a judgment on July 14, 1913, ordering the defendants to return the land and pay damages.
  • The defendants filed a motion for a new hearing, which Judge Johnston granted, scheduling it for September 9, 1913.
  • Tagal's attorney contested Johnston's authority to rule on the new trial, asserting that the prior judgment was final.
  • After several motions and hearings, Judge Johnston dismissed the case on September 22, 1913, prompting Tagal to file for a writ of mandamus, claiming Johnston exceeded his jurisdiction.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied Francisca Tagal's petition for a writ of mandamus.
  • The Court ruled that Judge Johnston retained the power to regain control of the case after the delegation to the justice of the peace expired.
  • The judgment by the justice of the peace was not final due to the timely ...(Unlock)

Ratio:

  • The Court's decision was based on Act No. 2131, which allowed justices of the peace to exercise jurisdiction through delegation from judges of the Court of First Instance.
  • The delegation is time-bound and can be revoked or expire, enabling the original judge to reclaim jurisdiction.
  • Since Johnston's delegation to Valdez had expi...continue reading

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