G.R. No. 27207, December 31, 1927
HEIRS OF FILOMENO ESQUIERES, applicants-appellants, vs. THE DIRECTOR OF LANDS, ET AL., oppositors; RUFINA NANAGAS, ET AL., oppositors-appellees.

DOCTRINE:
A judge who signs a judgment after being appointed to another judicial district is presumed to have acted within lawful jurisdiction, especially when there is no evidence rebutting the presumption that they were duly authorized to conclude the case.

FACTS

The heirs of Filomeno Esquieres filed an application for the registration of a 454-hectare land in San Narciso, Tayabas. The Director of Lands and the heirs of Ramon Pimentel opposed the application. The Court of First Instance of Tayabas, through Judge Plato, denied the application, finding that the land was covered by a possessory information title issued in favor of Ramon Pimentel. The heirs of Esquieres appealed, arguing that Judge Plato lacked jurisdiction to sign the judgment because, at the time of signing, he had already been appointed as a judge of the Court of First Instance of Albay.

ISSUE

Whether Judge Plato had jurisdiction to sign the judgment despite his appointment to another judicial district.

RULING

Yes, the judgment is valid. The Supreme Court affirmed the lower court’s decision. The Court held that there is a legal presumption that a judge acted in the lawful exercise of jurisdiction. The mere fact that Judge Plato signed as a judge of Albay does not rebut this presumption. He could have been authorized under Section 155 of the Administrative Code to finish the trial of the case after his transfer. In the absence of evidence to the contrary, the presumption of regularity stands. The Court also found the factual findings of the trial court to be supported by evidence. The appealed judgment was affirmed, with costs against the appellants.