People vs. Court of First Instance of Quezon, Br. X, Gumaca, Quezon, and Malco

A decision penned by a judge during his valid temporary detail to a vacant branch remains valid even if promulgated after his detail has expired, provided he is still an incumbent judge of the same court at the time of promulgation. The authority to decide cases submitted during the detail continues, and the judgment is considered that of the court itself, not of a separate entity.

Private respondent Gregorio Malco was charged with attempted rape before the Court of First Instance of Quezon, Branch X. After the case was submitted for decision, the presiding judge retired. Judge Juan B. Montecillo, the presiding judge of Branch III, was designated pro tempore to take over Branch X. Judge Montecillo decided the case, acquitting Malco, on 22 May 1978. On 10 June 1978, Judge Conrado R. Antona qualified as the new permanent Presiding Judge of Branch X, terminating Judge Montecillo's temporary designation. The decision was promulgated on 20 June 1978. The prosecution moved to set aside the judgment, arguing it was void because Judge Montecillo was no longer the judge-designate of Branch X when it was promulgated.

• Nature of the Case: Gregorio Malco was charged with attempted rape before the Court of First Instance (CFI) of Quezon, Branch X.
• Submission and Judicial Vacancy: After trial, the case was submitted for decision to the branch's presiding judge, who retired without deciding it.
• Temporary Designation: Judge Juan B. Montecillo, Presiding Judge of Branch III, was designated pro tempore to preside over Branch X. The case of Malco was among those submitted to him for decision.
• The Decision: Judge Montecillo penned a decision on 22 May 1978 acquitting Malco.
• Appointment of Permanent Judge: On 10 June 1978, Judge Conrado R. Antona qualified as the new permanent Presiding Judge of Branch X, thereby terminating Judge Montecillo's temporary designation.
• Promulgation: The decision was promulgated on 20 June 1978.
• Prosecution's Challenge: The prosecution moved to set aside the judgment, arguing it was null and void because Judge Montecillo's authority over Branch X had ceased before its promulgation. Judge Antona denied the motion, stating the trial court lacked jurisdiction to review a co-equal court's act.
• Lower Court's Reasoning: Judge Antona sustained the acquittal, implicitly adopting the judgment by denying the prosecution's motions.

• Nullity of Judgment: Petitioner (the People) argued that the appointment and qualification of Judge Antona immediately terminated Judge Montecillo's temporary designation. Consequently, the decision penned by Judge Montecillo and promulgated after his authority expired was null and void.
• Duty of the New Judge: Petitioner maintained that the trial court under Judge Antona should have set aside the void judgment of acquittal.

• Continuing Authority: Respondent (Malco) countered that Judge Montecillo, as an incumbent judge of the CFI of Quezon (assigned to Branch III), retained authority to decide cases submitted to him during his valid detail to Branch X, even after the detail ended.
• Jurisdiction of the Court: Respondent argued that jurisdiction is vested in the court, not in the individual judge or branch. Therefore, the decision was that of the CFI of Quezon, not of a separate court.
• Prohibition on Double Jeopardy: Respondent contended that annulling the valid acquittal would place him in double jeopardy.

• Validity of the Judgment: Whether the judgment of acquittal penned by a judge detailed to a vacant branch is valid when promulgated after his temporary designation has expired due to the appointment of a permanent judge.
• Authority of the Detailed Judge: Whether a judge whose temporary detail has expired retains authority to decide cases submitted to him during that detail.

• Validity of the Judgment: The judgment of acquittal was valid. Judge Montecillo penned the decision on 22 May 1978 while his temporary designation was still in effect. His authority to dispose of the case continued because he remained an incumbent judge of the same court (CFI of Quezon) at the time of promulgation. Jurisdiction is vested in the court, not in a particular branch or judge.
• Authority of the Detailed Judge: A judge whose temporary detail to a vacant branch has expired remains an incumbent judge of his permanent branch. He may validly decide cases submitted to him during his detail even after the vacancy is filled, as the authority stems from his incumbency in the same court. The Court cited its Resolution of 10 February 1983 implementing the Judiciary Reorganization Act, which provides that cases submitted for decision shall be decided by the judge to whom they were submitted, without requiring that the judge be the one who heard the case.

• Continuing Authority of a Detailed Judge — A judge temporarily detailed to a vacant branch retains authority to decide cases submitted to him during that detail even after the detail expires, provided he remains an incumbent judge of the same court. This ensures judicial efficiency and honors the judge's work during the valid assignment.
• Indivisibility of Court Jurisdiction — In a court with multiple branches (like the CFI/RTC), jurisdiction is vested in the court as a whole, not in any particular branch or judge. A case filed before one branch is a case of the entire court, and any branch's judge may validly decide it if properly submitted.

• "There is no law which prohibits a judge from deciding a case because he did not see some of the witnesses when they testified therein. In the absence of any express prohibition of this kind, we cannot imply one." — Citing United States v. Abreu, this underscores that a decision based on records is valid.
• "Jurisdiction is vested in the court, not in the judges, so that when a complaint or information is filed before one branch or judge, jurisdiction does not attach to said branch of the judge alone, to the exclusion of the others." — Articulates the doctrine of the indivisibility of court jurisdiction.
• "The Court frowns upon technicalities, especially so if these are used to put in jeopardy the acquittal of an accused who should be benefitted by a liberal construction of the rules." — Highlights the Court's preference for substantive justice over procedural technicalities in criminal cases, particularly where double jeopardy concerns arise.

• United States v. Abreu, 30 Phil. 402 (1915) — Controlling precedent establishing that a judge may validly decide a case based on the record even without having personally heard all the witnesses.
• People v. Gorospe, G.R. No. 51513 (1984) — Cited for the principle that jurisdiction is vested in the court, not in the judges, and that the filing of a case before one branch does not exclude other branches from acting on it.
• People v. Collado, G.R. No. 88631 (1991) — Cited as an example where a judge who did not try a case was permitted to decide it based on the record.

• Resolution of the Supreme Court En Banc, 10 February 1983 (Implementing B.P. Blg. 129) — Paragraph I, subparagraph 1, provides that cases already submitted for decision shall be decided by the judge to whom they were submitted. The Court interpreted this to mean the authoring judge need not be the judge who heard the case, nor need he be the presiding judge of that branch at the time of promulgation, as long as he is an incumbent judge.

• Justice Isagani A. Cruz
• Justice Hilario G. Davide, Jr.
• Justice Jose C. Quiason

N/A — The decision was unanimous.