Bacalso vs. Ramolete

Jurisdiction is vested in the Court of First Instance as a whole, not in its coordinate branches or individual judges; consequently, administrative directives from the Secretary of Justice regarding case apportionment among branches regulate internal workflow but do not confer, enlarge, or divest jurisdiction. Where subsequent legislation expressly provides that existing courts shall retain pending cases upon the creation of additional branches, the jurisdictional dispute is rendered moot, and the original branch rightfully continues to hear and decide the matter.

Celestino Bacalso filed a complaint in the Court of First Instance of Cebu challenging an administrative decision by the Secretary of Agriculture & Natural Resources that recognized superior location rights of Mateo C. Bacalso and Cesar Gonzalez over disputed mining claims in Toledo City. The case was docketed as Civil Case No. 7278 and assigned to Branch V. Following the creation of Branch VII in Barili, Cebu, the Secretary of Justice issued Administrative Orders Nos. 302 and 337, directing that cases originating from Toledo City be assigned to the newly created branch. The private respondents moved to transfer the pending litigation to Branch VII, alleging compliance with the administrative directive. The trial judge denied the transfer, citing prior case assignment and resolved pre-trial incidents. Petitioners subsequently sought prohibition to compel the transfer.

• Celestino Bacalso initiated Civil Case No. 7278 in the Court of First Instance of Cebu against the Secretary of Agriculture & Natural Resources, Mateo C. Bacalso, and Cesar Gonzalez, seeking to overturn an administrative ruling that favored the latter two regarding mining claims in Toledo City.
• The case was assigned to Branch V, presided over by respondent Judge Modesto R. Ramolete, prior to the creation of Branch VII in Barili, Cebu.
• The Secretary of Justice subsequently issued Administrative Order No. 302, distributing cases among eight CFI branches in Cebu, followed by Administrative Order No. 337, which specifically reassigned cases originating from Toledo City to Branch VII.
• Mateo C. Bacalso and Cesar Gonzalez filed an ex-parte motion to compel the clerk of court to transfer Civil Case No. 7278 to Branch VII, invoking the administrative orders.
• The trial judge denied the motion, reasoning that the case had been assigned to Branch V before Branch VII's creation, that multiple pre-trial incidents had already been resolved by Branch V, and that internal judicial agreements did not cover the transfer.
• Following the denial of the motion for reconsideration, petitioners filed a petition for prohibition with a prayer for preliminary injunction, seeking to compel the trial judge to comply with the Secretary of Justice's reassignment directive.

• Petitioners maintained that Administrative Orders Nos. 302 and 337 of the Secretary of Justice validly directed the transfer of all cases originating from Toledo City to Branch VII in Barili, Cebu.
• Petitioners argued that the trial judge's refusal to transfer the case contravened a lawful administrative directive and that compliance was necessary to align the litigation with the statutory expansion and geographic apportionment of the CFI branches.

• Respondent Judge and private respondent Celestino Bacalso countered that Branch V retained jurisdiction because the case was filed and assigned to it prior to the creation of Branch VII and the issuance of the administrative orders.
• Respondents emphasized that several substantive incidents had already been resolved by Branch V, and transferring the case would risk conflicting rulings and disrupt judicial efficiency.
• Respondents further asserted that internal agreements among CFI judges regarding case assignments, coupled with the court's prior assumption of jurisdiction, justified retaining the case in Branch V.

• Procedural Issues: Whether the petition for prohibition is the proper remedy to compel a trial judge to transfer a pending case to another branch pursuant to an administrative order of the Secretary of Justice, and whether the enactment of subsequent legislation rendered the controversy moot.
• Substantive Issues: Whether the administrative apportionment of cases among branches of the same court by the Secretary of Justice confers exclusive jurisdiction to a specific branch or divests another branch of jurisdiction over cases already pending before it.

• Procedural: The Court dismissed the petition for prohibition and dissolved the preliminary injunction, holding that the jurisdictional question had become moot and academic. The enactment of Republic Act No. 3729, which explicitly provided that existing courts shall retain jurisdiction over cases already filed upon the establishment of additional branches, resolved the underlying dispute. Accordingly, judicial intervention was no longer necessary.
• Substantive: The Court ruled that jurisdiction is constitutionally and statutorily vested in the Court of First Instance as a single judicial entity, not in its individual branches or judges. The Secretary of Justice's authority under Section 57 of the Judiciary Act to apportion cases among branches is strictly administrative and intended for convenience and coordination; it does not alter, enlarge, or diminish the court's jurisdictional grant. While the trial judge erred in asserting exclusive jurisdiction based on prior assignment and internal agreements, the administrative directive to transfer cases does not strip the original branch of its institutional jurisdiction.

• Institutional Jurisdiction of Coordinate Branches — Jurisdiction attaches to the court as an institution, not to a specific branch or presiding judge. All branches of a Court of First Instance within a judicial district are coordinate and co-equal; proceedings may validly continue before any branch or judge of the same court. Administrative reassignment of pending cases among branches regulates internal docket management but does not transfer or divest jurisdiction, which remains vested in the court as a whole.
• Mootness Doctrine — A legal controversy ceases to be justiciable when a supervening event, such as the enactment of a statute that expressly resolves the disputed issue, eliminates the necessity for a judicial declaration. The Court will not rule on moot questions unless an exception applies, and here, the statutory retention of pending cases by the original branch rendered the jurisdictional challenge academic.

• "It is trite to say, however, that the validity of a given judicial action is dependent upon the jurisdiction of the court taking it, and that, by specific constitutional mandate, the power to define, prescribe and apportion the jurisdiction of the various courts, is subject to the limitations set forth in the fundamental law, within the exclusive province of Congress." — The Court invoked this principle to establish that jurisdictional grants originate solely from the Constitution and legislative enactments, and cannot be modified by administrative orders or judicial agreements.
• "The jurisdiction is vested in the court, not in the judges. And when a case is filed in one branch jurisdiction over the case does not attach to the branch or judge alone, to the exclusion of the other branches. Trial may be held or proceedings continue by and before another branch or judge." — This passage articulates the foundational rule that coordinate branches share a single institutional jurisdiction, rendering claims of exclusive branch jurisdiction legally untenable.
• "Wherever an additional branch or branches of the Court of First Instance is or are established in this Act in the same place where there is an existing court or courts of first instance, all cases already filed in the latter court or courts shall be heard, tried and decided by such latter court or courts." — The Court cited this statutory provision from R.A. No. 3729 to demonstrate that the legislature expressly preserved the original branch's authority over pending cases, thereby mooting the transfer dispute.

• Gumpal v. CFI of Isabela, et al. (G.R. Nos. L-16409 and L-16416, November 29, 1960) — Cited as controlling precedent to affirm that the power to define, prescribe, and apportion judicial jurisdiction belongs exclusively to Congress under the Constitution, and cannot be delegated to the Secretary of Justice or altered by judicial fiat or internal court agreements.

• Section 57 of the Judiciary Act — Grants the Secretary of Justice the administrative authority to apportion and distribute cases among the different branches of the same court for the convenience of the parties and coordination of judicial work, without affecting the court's jurisdictional vesting.
• Republic Act No. 2613 — The legislative act that increased the number of CFI branches in Cebu from six to eight, prompting the Secretary of Justice to issue implementing administrative orders for case distribution.
• Administrative Order Nos. 302 and 337 (Series of 1962) — Issued by the Secretary of Justice to implement the statutory expansion by assigning Toledo City-originating cases to Branch VII in Barili, Cebu.
• Republic Act No. 3729 — Amended the Judiciary Act of 1948 (R.A. No. 296) to increase the number of CFI branches in the 14th Judicial District and explicitly mandated that existing courts retain jurisdiction over cases already filed, thereby resolving the jurisdictional conflict.