G.R. No. L-23584-85 August 31, 1971
THE PEOPLE OF THE PHILIPPINES and LOURDES ITCHON VDA. DE FORMOSO, petitioners, vs. HON. ANGELINO C. SALANGA, Judge, Court of First Instance of Ilocos Sur, TERIO PERALTA, alias “LEPROSO”, LUCIO FABILLARAN and JOHNNY FABILLARAN, respondents.

FACTS

Criminal Cases Nos. 3692 and 3965 for double murder and double attempted murder were filed in 1958 and initially assigned to Branch I of the Court of First Instance of Ilocos Sur in Vigan, presided by Judge Felix Antonio. After the accused pleaded not guilty and were granted separate trials, Judge Antonio commenced hearings. Following judicial reorganizations and a raffle among new judges, the cases were later assigned to Branch III. Judge Angelino Salanga, presiding Branch III, partially heard the cases. Subsequently, Judge Salanga was appointed to preside over the newly-created Branch IV in Candon. Judge Deogracias Solis replaced him in Branch III. On June 15, 1964, the Secretary of Justice issued Administrative Order No. 184, authorizing Judge Salanga to continue holding court in Vigan. Judge Solis, upon learning Judge Salanga had partially heard the cases, endorsed them to Branch I, which Judge Salanga was then presiding in Vigan under the administrative order.

ISSUE

Whether respondent Judge Angelino Salanga had the authority and jurisdiction to continue hearing and decide the criminal cases after his transfer to another branch and station.

RULING

The Supreme Court ruled that Judge Salanga had the authority to continue trying the cases. The legal logic rests on the interpretation of Section 51 of the Judiciary Act of 1948, as amended, and Section 9 of Rule 135 of the Rules of Court. These provisions allow a judge who has partly heard a case to continue hearing and decide it, notwithstanding a transfer to another court of equal jurisdiction, provided there is authorization from the Supreme Court. The Court clarified that Administrative Order No. 184 from the Secretary of Justice, which permitted Judge Salanga to hold court in Vigan, did not by itself confer the specific authority required by law to continue a partly heard case. However, the Court found that the factual circumstances and the endorsement by Judge Solis, effectively recommending Judge Salanga to continue, substantially complied with the procedural requirement of a “recommendation of the respective district judge” as stipulated in the law. The Court emphasized that the law aims to prevent delays and ensure the efficient administration of justice by allowing the judge familiar with the proceedings to conclude them. Since no other judge had heard the case in part after Judge Salanga, and to avoid further prejudice and delay, his continuation was deemed legally permissible under the spirit and intent of the governing statutes.