G.R. No. 1810 : April 22, 1904
EULOGIO GARCIA, petitioner, vs. B. S. AMBLER AND JOHN C. SWEENEY, respondents.

FACTS:
In a civil action (Marker vs. Garcia), Judge B. S. Ambler rendered judgment against Eulogio Garcia on May 1, 1903. Garcia timely filed a bill of exceptions with the court clerk on July 3, 1903, following the denial of a motion for new trial. However, Judge Ambler was absent from the Philippines at the time. Upon his return, Judge Ambler refused to approve the bill of exceptions, insisting that the caseoriginally tried in Part III of the Court of First Instance of Manilarequired a formal order of transfer to Part I, where he was then presiding. Judge John C. Sweeney, presiding over Part III, deemed such a transfer unnecessary and improper, arguing that Judge Ambler, as the trial judge, retained authority to approve the bill regardless of the part. Consequently, both judges declined to act, leaving the bill unapproved. Garcia petitioned the Supreme Court for a writ of mandamus to compel Judge Sweeney to issue the transfer order (if deemed necessary) and to compel Judge Ambler to approve and certify the bill of exceptions.

ISSUE:
Whether a writ of mandamus should issue to compel Judge Ambler to approve and certify the bill of exceptions, notwithstanding the administrative distribution of cases between different parts of the Court of First Instance of Manila.

RULING:
Yes. The Supreme Court granted the writ of mandamus directed at Judge Ambler, ordering him to allow and certify the bill of exceptions. The Court held:
1. The bill of exceptions was filed within the period prescribed by law (Section 143, Code of Civil Procedure). Delivery to the court clerk constituted presentation to the court, as the clerk acts under the court’s authority and must report filings to the judge.
2. The Court of First Instance of Manila is a single court, despite being divided into parts for administrative convenience. The distribution of cases among judges is a matter of internal rules and does not affect jurisdiction. Any judge of the court may act in a case assigned to another when necessary.
3. The trial judge (Judge Ambler) has the primary duty to approve the bill of exceptions. His refusal based on the lack of a transfer order was unjustified, as no such order was legally required. Judge Sweeney’s non-opposition further negated any need for transfer.
4. Procedural rules should be interpreted liberally to serve their purposeensuring justice and allowing appealsrather than technically denying a party’s right to appeal.
The writ was issued against Judge Ambler, with costs de oficio.

Note: Justice Johnson dissented without opinion.