G.R. No. L-10292; March 31, 1915
EUSTAQUIO CONCHADA, petitioner, vs. THE DIRECTOR OF PRISONS, respondent.

FACTS:
On May 19, 1914, Eustaquio Conchada was charged with murder in the Court of First Instance of Tayabas, Seventh Judicial District. The case was later tried on July 23, 1914, before the same court, but by then presided over by Judge Isidro Paredes. This change occurred because Act No. 2347 of the Philippine Legislature, effective July 1, 1914, had reorganized the Courts of First Instance, placing Tayabas under the Fourteenth Judicial District. Conchada was convicted and sentenced to life imprisonment on September 23, 1914. During the trial, Conchada filed a motion arguing that the court lacked jurisdiction because Act No. 2347 was unconstitutional, as it abolished the “constitutional court” created under the Organic Act and replaced it with a legislatively created court. The motion was denied. Conchada subsequently petitioned the Supreme Court for a writ of habeas corpus, contending that his conviction was null and void due to the court’s lack of jurisdiction.

ISSUE:
Whether Act No. 2347, which reorganized the Courts of First Instance, is unconstitutional for allegedly abolishing the “constitutional courts” established under the Organic Act and for removing judges without authority, thereby depriving the reorganized court of jurisdiction to try and sentence Conchada.

RULING:
The Supreme Court denied the petition for habeas corpus. It held that the Courts of First Instance are not “constitutional courts” in the same sense as the Supreme Court. The Organic Act (Philippine Bill of 1902) and the earlier judiciary Act ( Act No. 136 ) did not fix the number of judicial districts, the provinces comprising them, or the tenure of judges in a manner that restricts legislative reorganization. The Philippine Legislature had the authority to reorganize the Courts of First Instance, including redistricting and reassigning judges, as an exercise of its power over the judiciary’s administrative structure. The Supreme Court distinguished itself as a constitutional court whose composition and sessions are governed by acts of the U.S. Congress, whereas the Courts of First Instance are subject to legislative reorganization by the Philippine Legislature. Therefore, Act No. 2347 was valid, Judge Paredes had jurisdiction, and Conchada’s conviction was lawful. The writ of habeas corpus was accordingly refused.