GR 31926; (May, 1981) (Digest)
G.R. No. L-31926 May 27, 1981
BUENO INDUSTRIAL & DEVELOPMENT CORPORATION, petitioner, vs. HON. MANUEL LOPEZ ENAGE, R.C. AQUINO TIMBER & PLYWOOD CO., INC. and RAFAEL C. AQUINO, respondents.
FACTS
The case originated from Special Civil Case No. 168 filed in the Court of First Instance (CFI) of Agusan. After extensive proceedings, including hearings on a preliminary injunction, a Supreme Court decision in a related case (G.R. No. L-23183), and pre-trial, the case was reassigned to respondent Judge Manuel Lopez Enage of Branch II, CFI of Agusan del Norte and Butuan City. The judge actively presided, issuing orders to enforce the Supreme Court’s prior decision and setting continuous hearings.
Subsequently, the province of Agusan was divided into Agusan del Norte and Agusan del Sur by Republic Act No. 4979 . Republic Act No. 6092 then created the CFI of Agusan del Sur. The forest lands subject to the litigation were within the new province of Agusan del Sur. Despite an opinion from the Department of Justice that he retained jurisdiction over cases filed before the new court’s creation, Judge Enage issued an order transferring the case to the CFI of Agusan del Sur, stating he no longer had jurisdiction.
ISSUE
Whether the respondent judge, having properly acquired jurisdiction over the case prior to the legislative division of the province and creation of a new court, lost jurisdiction and was required to transfer the case.
RULING
The Supreme Court granted the petition, ordering the CFI of Agusan del Norte, Branch II, to proceed with the case. The legal logic is anchored on the fundamental doctrine that jurisdiction, once lawfully acquired by a court over a case, continues until the final termination of the proceedings, absent an express statutory provision mandating otherwise. No such express provision was found in Republic Act Nos. 4979 or 6092 that would divest the originally vested court of its authority over pending cases.
The Court emphasized the significant judicial economy and convenience in maintaining jurisdiction, noting the case had progressed extensively through partial trial on the merits, pre-trial, and orders for damage assessment. The respondent judge’s insistence on transferring the case, despite administrative guidance from the Department of Justice to retain it, constituted an unnecessary quibble that would cause great inconvenience and complication for the parties. The Supreme Court set aside the challenged orders, reinstating jurisdiction in the court that had originally and properly acquired it.