G.R. No. 32723 / October 15, 1930
THE PEOPLE OF THE PHILIPPINE ISLANDS vs. HERMENEGILDO TRIA

FACTS

The defendant-appellant, Hermenegildo Tria, was convicted by a division of the Supreme Court composed of four justices. His counsel filed a motion contending that the divisional court lacked jurisdiction because four justices did not constitute the required quorum under Section 163 of Act No. 2657 (the former Administrative Code), which prescribed a quorum of five justices for the Supreme Court. The division referred the case to the full court to resolve this fundamental issue.

ISSUE

Whether a division of the Supreme Court composed of four justices has jurisdiction to decide cases, notwithstanding the quorum requirement of five justices under the former Administrative Code.

RULING

Yes. The Supreme Court en banc upheld the validity of the divisional court’s composition and jurisdiction. The Court ruled that:
1. The provision in the Jones Law confirming the jurisdiction of the Supreme Court referred to its authority to hear and determine cases, not to procedural details such as the number of justices or the quorum required. These are matters of procedure that the Philippine Legislature may regulate.
2. Section 138 of the present Administrative Code, which authorizes the Supreme Court to sit in divisions, is a valid procedural regulation. It does not diminish the Court’s jurisdiction but merely organizes it for convenience and prompt dispatch of business.
3. The Supreme Court remains a single tribunal even when working in divisions. The divisional court’s decisions are effectively decisions of the Supreme Court itself.
4. The increase in the number of justices from seven to nine allowed the Legislature to set a quorum of four justices for divisions, which is the maximum possible number for a division given the Court’s composition. This does not reduce the quorum for the Court in banc, which was increased to six.
Thus, the motion to submit the case to the Court in banc for a new decision was denied.