Case Digest (G.R. No. L-30158)
Facts:
Valentin v. Santa Maria, G.R. No. L-30158, January 17, 1974, Supreme Court En Banc, Fernando, J., writing for the Court. Petitioner Lorenzo G. Valentin was defendant in Civil Case No. 2586, Court of First Instance (CFI) of Bulacan, entitled Yolanda Matias v. Lorenzo G. Valentin. On December 20, 1963 Judge Samuel F. Reyes (who had by then assumed office as District Judge for Rizal, Branch X) promulgated a judgment in favor of plaintiff Yolanda Matias nullifying Transfer Certificate of Title No. T-32568, declaring petitioner a possessor in bad faith, ordering accounting for fruits from May 2, 1961, awarding P1,000 attorney’s fees and costs, and directing registry actions by the Register of Deeds of Bulacan.That decision was appealed to the Court of Appeals (C.A. G.R. No. 34166‑R), which affirmed the CFI decision on May 13, 1968, and denied appellant’s motion for reconsideration on July 19, 1968. Upon discovering that Judge Reyes had already qualified as judge in Rizal at the time he promulgated the December 20, 1963 decision, petitioner filed on October 26, 1968 in the CFI of Bulacan, before respondent Judge Andres Santa Maria, a “Motion to Disregard Judgment of December 20, 1963 and to Render Judgment Anew,” invoking People v. Soria (G.R. L‑25175, Mar. 1, 1968). Private respondent opposed the motion (Oct. 29, 1968). Judge Santa Maria denied the motion on December 12, 1968; a motion for reconsideration was also denied.
Petitioner then sought relief from the Supreme Court by a petition for certiorari and mandamus filed February 10, 1969, asking the Court to declare Judge Reyes’s December 20, 1963 decision void under the Soria doctrine and to compel respondents to disregard it. While this petition was pending, the Court in People v. Donesa (G.R. L‑24162, Jan. 31, 1973) declined to give retroactive effect to Soria, and a concurring opinion in Donesa by Justice Teehankee (joined by five other justices) st...(Subscriber-Only)
Issues:
- Can petitioner successfully invoke the doctrine in People v. Soria to have a judgment rendered by a judge who had already assumed office elsewhere declared null and void?
- Does the second paragraph of Section 51 of the Judiciary Act (as amended) permit a judge permanently transferred or assigned to another court of equal jurisdiction to prepare and sign a decision in a case totally heard by him anywhere in the Philippines and send it by registered mail for filing (i.e., should ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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