G.R. No. 168639 ; January 29, 2007
ALDERITO Z. YUJUICO, BONIFACIO C. SUMBILLA, and DOLNEY S. SUMBILLA, Petitioners, vs. CEZAR T. QUIAMBAO, JOSE M. MAGNO III, MA. CHRISTINA F. FERREROS, ANTHONY K. QUIAMBAO, SIMPLICIO T. QUIAMBAO, JR., ERIC C. PILAPIL, ALBERT M. RASALAN, and REGIONAL TRIAL COURT, BRANCH 48, URDANETA CITY, Respondents.

FACTS

Strategic Alliance Development Corporation (STRADEC) held its annual stockholders’ meeting on March 1, 2004, at its office in Pasig City, as indicated in the notices. Petitioners and some respondents were elected as directors. Five months later, respondents filed a complaint with the Regional Trial Court (RTC) of San Carlos City, Pangasinan, seeking to nullify the election on the ground of improper venue. They argued that STRADEC’s principal office, as per an amended Articles of Incorporation approved in 1998, was in Bayambang, Pangasinan, making the Pasig meeting void under Section 51 of the Corporation Code. The case, an intra-corporate dispute, was transferred to the RTC of Urdaneta City, Branch 48, a designated Special Commercial Court.
While the newly appointed presiding judge for Branch 48 had already assumed office, the pairing judge who had been temporarily handling the branch proceeded to rule on pending motions. On November 25, 2004, the pairing judge issued an Order granting respondents’ application for a writ of preliminary injunction. The order directed the holding of a special stockholders’ meeting in Bayambang, Pangasinan, and required a petitioner to turn over a key to a safety deposit box containing corporate records.

ISSUE

Whether the pairing judge had the authority to issue the November 25, 2004 Order granting the preliminary injunction after the regular presiding judge had already been appointed and had assumed office.

RULING

The Supreme Court ruled that the pairing judge acted without jurisdiction. The legal logic is anchored on the principle that a judge’s authority to act in a case ceases upon the appointment and qualification of the regular judge. The regular presiding judge of RTC Branch 48, Urdaneta City, took his oath on November 9, 2004, and assumed his duties on November 12, 2004. Consequently, as of November 12, the pairing judge’s temporary authority over the court and its cases terminated. All judicial functions reverted to the newly installed regular judge. The Order dated November 25, 2004, was therefore issued by a judge who no longer possessed any judicial power over the case, rendering it null and void. The Court emphasized that jurisdiction is conferred by law, and orders issued without jurisdiction have no legal effect. The subsequent actions of the regular judge in adopting the void order did not cure this fatal defect. The case was remanded to the regular presiding judge of RTC Branch 48 for proper proceedings.