ABC Davao Auto Supply, Inc. vs. Court of Appeals

Jurisdiction attaches to the court, not to the judge. The Court held that a decision rendered by a judge who has been transferred to another branch of the same court is valid, provided the judge remains an incumbent member of that court at the time of promulgation, and any defect arising from the judge's transfer is cured when the newly assigned presiding judge adopts the decision by denying a motion for reconsideration.

Davao Sugar Central Company contracted private respondent Abundio T. Merced to repair its trailers. Merced purchased vehicular parts on credit from petitioner ABC Davao Auto Supply, Inc., with an agreement that payments were due within 30 days, subject to 12% interest and 25% attorney's fees upon default. Merced incurred an outstanding balance of P99,217.15 but refused payment, claiming the accounts had not yet matured. Petitioner filed a complaint for a sum of money, attorney's fees, and damages before the Court of First Instance of Davao City.

• The Underlying Obligation: Private respondent Abundio T. Merced, doing business as Southern Engineering Works, purchased vehicular parts on credit from petitioner ABC Davao Auto Supply, Inc., leaving an outstanding balance of P99,217.15. Upon demand, private respondent refused to pay, alleging the accounts had not yet matured.
• The Trial Court Proceedings: Petitioner filed a collection suit on October 6, 1980, in the Court of First Instance (later RTC) of Davao City, Branch XVI. The case underwent pre-trial and trial before several judges due to reorganizations and reassignments. Judge Roque Agton assumed office in Branch XVI on August 1, 1985, and heard the cross-examination and rebuttal evidence.
• The Judicial Reorganization: Following the judicial reorganization under the Aquino administration, Judge Agton was transferred to RTC Branch 6 in Mati, Davao Oriental, within the same judicial region. Judge Romeo Marasigan assumed office as presiding judge of Branch XVI on February 3, 1987. In May 1987, Judge Marasigan acted on private respondent's motion for extension of time to file a memorandum. The parties submitted their memoranda in March 1987.
• The Contested Judgment: On June 9, 1987, Judge Agton rendered a decision in favor of petitioner. Private respondent moved for reconsideration, which Judge Marasigan denied on March 1, 1988, thereby adopting Judge Agton's decision in toto.
• The Appellate Ruling: Private respondent appealed to the Court of Appeals. The Court of Appeals nullified Judge Agton's decision, holding that at the time he rendered judgment, he was neither the judge de jure nor the judge de facto of RTC Branch XVI. The appellate court remanded the case to the trial court.

• Petitioner argued that the decision of Judge Agton is valid.
• Petitioner contended that jurisdiction attaches to the court, not to the judge, and therefore Judge Agton did not lose jurisdiction over the case simply because he was transferred to another branch within the same judicial region.

• Respondent argued that Judge Agton's decision was invalid because he was neither the judge de jure nor the judge de facto of RTC Branch XVI at the time he rendered the judgment.
• Respondent contended that because the case was submitted for decision in March 1987, when Judge Marasigan was already the presiding judge of Branch XVI, the case was submitted to Judge Marasigan, rendering Judge Agton's decision improper.

• Procedural Issues: N/A
• Substantive Issues:
  • Whether the decision rendered by a judge who had been transferred to another branch within the same court, but who was no longer the presiding judge of the branch where the case was pending at the time of promulgation, is valid.
  • Whether jurisdiction over a case attaches to the individual judge or to the court.

• Procedural: N/A
• Substantive:
  • The Court held that Judge Agton's decision is valid and must be reinstated.
  • Although the case was submitted for decision in March 1987 when Judge Marasigan was already presiding—making Judge Agton's act of deciding the case appear tainted with impropriety—Judge Marasigan subsequently denied the motion for reconsideration of Agton's decision. This denial indicated that Judge Marasigan subscribed to and adopted the decision in toto, thereby curing any incipient defect. The presumption that both judges regularly performed their official duties was unrebutted.
  • For a judgment to be binding, it must be signed and promulgated during the incumbency of the judge whose signature appears thereon. Pursuant to the Court's En Banc Resolution implementing B.P. 129, the judge need only be an incumbent judge of the same court, albeit assigned to a different branch, at the time of promulgation. Because branches of a trial court are not distinct and separate tribunals, Judge Agton did not lose jurisdiction over the case.
  • Jurisdiction attaches to the court, not to the judge. The continuity of a court and the efficacy of its proceedings are not affected by the death, resignation, or cessation from service of the presiding judge. Remanding the case would only prolong the litigation and contravene the policy of just, speedy, and inexpensive disposition of cases.

• Jurisdiction Attaches to the Court, Not to the Judge — The continuity of a court and the efficacy of its proceedings are not affected by the death, resignation, or cessation from service of the judge presiding over it. A judge who is transferred to another branch within the same court does not lose jurisdiction over cases decided in the original branch, because branches of a trial court are not distinct and separate tribunals.
• Validity of Judgments by Transferred Judges — For a judgment to be binding, it must be duly signed and promulgated during the incumbency of the judge whose signature appears thereon. Under B.P. 129, the judge who pens the decision need only be an incumbent judge of the same court, albeit assigned to a different branch, at the time the decision is promulgated.
• Adoption of Decision by Successor Judge — Where a judge renders a decision in a case that had already been submitted to his successor, any defect in the promulgation is cured when the successor judge denies a motion for reconsideration of that decision, thereby adopting it in toto.

• "Jurisdiction does not attach to the judge but to the court. The continuity of a court and the efficacy of its proceedings are not affected by the death, resignation, or cessation from the service of the judge presiding over it." — This passage articulates the fundamental principle that court jurisdiction is independent of the individual presiding judge, ensuring the uninterrupted function of the judicial system despite changes in personnel.
• "Branches of the trial court are not distinct and separate tribunals from each other. Hence, contrary to private respondent's allegation, Judge Agton could not have possibly lost jurisdiction over the case, because jurisdiction does not attach to the judge but to the court." — This clarifies the organizational structure of trial courts, establishing that intra-regional transfers do not divest a judge of authority over previously heard matters.

• People v. CFI of Quezon, Branch X, 227 SCRA 457 (1993) — Followed. The Court relied on this case to establish that under the En Banc Resolution implementing B.P. 129, a judge who pens a decision need only be an incumbent judge of the same court, albeit assigned to a different branch, at the time the decision is promulgated. It was also cited for the principle that jurisdiction attaches to the court and not to the judge.
• People v. Labao, 220 SCRA 100 (1993); Lao v. To-Chip, 158 SCRA 243 (1988) — Followed. Cited for the rule that a judgment must be signed and promulgated during the incumbency of the judge whose signature appears thereon.
• People v. Gorospe, 129 SCRA 233; Lumpay v. Moscoso, 105 Phil. 968 — Followed. Cited in support of the principle that branches of a trial court are not distinct and separate tribunals.

• Rule 131, Section 3(m), Rules of Court — Presumption of regular performance of official duties. The Court applied this presumption to the actions of both Judge Agton and Judge Marasigan, noting that private respondent failed to rebut it with contrary evidence.
• Batas Pambansa Blg. 129, as implemented by the En Banc Resolution of February 10, 1983 — Governs the authority of judges to decide submitted cases. The Court applied the provision stating that cases already submitted for decision shall be decided by the judge to whom they were submitted, except where the judge is promoted or no longer in service. The Court interpreted this to mean the deciding judge must only be an incumbent judge of the same court at the time of promulgation.
• Rule 1, Section 6, Rules of Court — Policy of just, speedy, and inexpensive disposition of every action. The Court applied this provision to justify reinstating the validly decided case rather than remanding it, which would unduly prolong the litigation.

Narvasa, C.J., Romero, Melo, and Panganiban, JJ.