GR 151160; (November, 2004) (Digest)
G.R. No. 151160 ; November 11, 2004
SPOUSES JOSE and ESTER MARCHADESCH, FELIX VILLAMOR, and REV. FR. MANUEL GOMEZ, petitioners, vs. JUANITA CINCO VDA. DE YEPES, respondent.
FACTS
Respondent Juanita Cinco Vda. de Yepes filed a complaint for ownership, possession, and annulment of documents against petitioners. She alleged she was the conjugal owner of a parcel of land in Tanauan, Leyte, acquired by sale in 1966. She claimed petitioners, who were occupying portions of the land, refused to vacate and asserted ownership based on subsequent sales among themselves. The case was tried before Judge Godofredo P. Quimsing of the RTC, Branch 6, Palo, Leyte, and was submitted for decision on October 6, 1986.
Judge Quimsing resigned in January 1987. He was later reappointed as Presiding Judge of RTC, Branch 33, Calbiga, Samar, in July 1990. In 1991, the records of undecided cases from his former sala, including this case, were sent to him. Upon request and with authorization from the Court Administrator, he decided the case on December 12, 1991, ruling in favor of the respondent. Petitioners appealed, contending Judge Quimsing had lost authority to decide the case after his resignation.
ISSUE
Whether Judge Godofredo P. Quimsing had the authority to decide Civil Case No. 6822 on December 12, 1991, after having resigned from his original post and subsequently being reappointed to a different branch.
RULING
The Supreme Court ruled that Judge Quimsing validly decided the case. The legal logic hinges on the application of Rule 135, Section 9 of the Rules of Court and relevant Supreme Court resolutions. The rule provides that a judge may, within a limited period, decide cases heard by him even after his transfer or appointment to another court of equal jurisdiction, provided he remains an incumbent judge.
Here, while Judge Quimsing resigned, his subsequent reappointment as an RTC judge in Calbiga, Samar, restored his status as an incumbent judge of a court of equal jurisdiction. The Court’s Resolution in A.M. No. 91-11-2014-RTC, which granted his request to decide the pending cases from his former sala, expressly affirmed his authority to do so. The principle ensures the efficient administration of justice by allowing a judge familiar with the proceedings to render the decision, preventing delay and the need for a new trial. Therefore, his decision was validly rendered, and the Court of Appeals’ affirmation of such authority was correct. The petition was denied.