Title
ABC Davao Auto Supply, Inc. vs. Court of Appeals
Case
G.R. No. 113296
Decision Date
Jan 16, 1998
A judge's decision remains valid despite transfer to another branch; jurisdiction lies with the court, not the individual judge, ensuring judicial efficiency.
A

Case Summary (G.R. No. 113296)

Judicial reorganization and subsequent assignments

During the judiciary reorganization under the Aquino administration, Judge Agton was transferred to a different RTC branch within the same judicial region (assigned to Branch 6, Mati, Davao Oriental). Judge Romeo Marasigan assumed office as presiding judge of Branch XVI on February 3, 1987. Records indicate Judge Agton’s appointment history and subsequent designation to another branch and eventual retirement, as well as Judge Marasigan’s assumption of Branch XVI.

Submission for decision and the contested judgment

The record shows that the parties filed memoranda and that the case was submitted for decision in March 1987, a time at which Judge Marasigan was already presiding in Branch XVI. Nonetheless, a decision bearing the signature of Judge Agton was rendered in favor of petitioner on June 9, 1987. Private respondent moved for reconsideration; Judge Marasigan denied the motion in an order dated March 1, 1988. Private respondent appealed to the Court of Appeals (CA), which nullified Judge Agton’s decision on the ground that at the time he rendered judgment he was neither judge de jure nor judge de facto of RTC Branch XVI, and remanded the case to the trial court.

Issue before the Supreme Court

The sole issue presented to the Supreme Court was whether Judge Agton’s decision was valid despite his reassignment at the time of promulgation.

Rule on submission for decision and initial assessment of validity

The Court recognized the controlling rule that a case is deemed submitted for decision upon the filing of the last pleading, brief, or memorandum required by the rules or by the court. Records reflected that submission occurred in March 1987 after memoranda were filed, when Judge Marasigan was already presiding in Branch XVI. On that basis, the Court acknowledged that prima facie the case had been submitted to Judge Marasigan and not to Judge Agton, which initially suggested that Judge Agton’s later promulgation could be tainted with impropriety.

Curing of any incipient defect and presumption of regularity

Despite the initial impropriety, the Supreme Court emphasized that Judge Marasigan thereafter acted on the motion for reconsideration (filed against Judge Agton’s decision) and denied it, thereby adopting Judge Agton’s decision in toto. The Court treated this subsequent action by the incumbent presiding judge as curing any incipient defect in Judge Agton’s promulgation. The ruling also relied on the presumption that magistrates regularly perform their official duties, a presumption which was not rebutted by contrary evidence in the record.

Signature and promulgation requirement; effect of reassignment

The Court reiterated the rule that for a judgment to be binding it must be duly signed and promulgated during the incumbency of the judge whose signature appears thereon. In line with the Court En Banc resolution implementing B.P. Blg. 129 (February 10, 1983), the Court observed that it is sufficient that the judge who pens the decision remains an incumbent judge of the same court at the time the decision is promulgated, even if assigned to a different branch. The decision also stressed

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.