G.R. No. L-7928, December 27, 1913
THE PROVINCE OF TARLAC, GREGORIO ROMULO, and JOSE TOPACIO, plaintiffs, vs. HERBERT D. GALE, defendant.

FACTS:
The plaintiffs, the Province of Tarlac and certain provincial officials, filed a petition for a writ of certiorari against the respondent Judge of the Court of First Instance of Tarlac. They sought to annul several orders issued by the judge. These orders commanded the plaintiffs to: (1) remove a partition they had erected in the court room; (2) eject an internal revenue agent from the judge’s chamber; (3) provide specific furniture, supplies, and stationery for the court; and (4) show cause why they should not be punished for contempt for failing to comply.

The plaintiffs demurred to the judge’s answer, arguing that the material facts were admitted and that the orders were issued without legal authority. The facts, as stated in the answer and treated as admitted for the demurrer, revealed that the provincial officials had significantly impaired the court’s functionality. They had taken away the judge’s chamber and given it to a revenue agent, erected a noisy partition that reduced the court room by one-third, and consistently failed to provide necessary furniture, stationery, and supplies (like a typewriter and postage) despite having funds for other non-essential projects. The provincial board had expressed the view that furnishing quarters for the court was merely a courtesy, not an obligation.

ISSUE:
Whether a judge of the Court of First Instance has the inherent power and authority to issue mandatory orders to provincial officials to provide adequate court facilities, furniture, and supplies essential for the proper administration of justice.

RULING:
YES. The Supreme Court sustained the authority of the respondent judge and dismissed the petition for certiorari.

The Court held that the power to administer justice is vested by law in the courts. This power carries with it, by necessary implication, all authority essential to its effective exercise. This includes the inherent power to compel the performance of acts necessary for the court to function properly and maintain its dignity, efficiency, and independence.

The Court ruled that it is an absolute duty of the provincial government, under the law, to provide suitable court rooms, chambers, and necessary supplies for the Court of First Instance. This duty is not discretionary or a mere courtesy. The provincial board cannot, through inaction or refusal, cripple the judicial branch.

Therefore, when provincial officials fail in this mandatory duty, the judge has the right and the power, as an incident of his judicial authority, to issue the necessary orders to secure what is indispensable for the court’s operation. The orders in question were not an attempt to control provincial discretion in administrative matters but were a lawful exercise of judicial power to command the performance of a plain legal duty essential to the existence and function of the court itself.

Note: The digest synthesizes the majority opinion. The provided text includes a dissenting opinion arguing that the judge’s orders violated the principle of co-equal branches by spending provincial funds without the provincial board’s prior authorization and that the plaintiffs deserved a full hearing on the facts.