G.R. No. L-9767; February 5, 1915
FRANCISCA TAGAL, petitioner, vs. C. D. JOHNSTON, Judge of First Instance, MANUEL BARICAUA, JACOBO TUMACAY and RAYMUNDO GAFFUD, respondents.

FACTS:
Petitioner Francisca Tagal filed an action for recovery of possession of agricultural land and damages against respondents Manuel Baricaua, Jacobo Tumacay, and Raymundo Gaffud in the Justice of the Peace Court of Enrile, Cagayan. The judgment was in favor of Tagal, and the defendants appealed to the Court of First Instance (CFI).

Judge C.D. Johnston of the CFI, to enable his vacation, delegated authority to Justice of the Peace Ramon Valdez of Tuguegarao (provincial capital) to try and decide the case pursuant to Act No. 2131 . Justice Valdez, acting as a judge by delegation, heard the evidence and rendered judgment on July 14, 1913, ordering defendants to restore the land to Tagal and pay damages.

The defendants filed a motion for a new trial on July 18, 1913. Judge Johnston, after the delegation period had expired, assumed jurisdiction, granted the motion for a new trial, and set the case for rehearing. Tagal objected, arguing that Judge Johnston no longer had jurisdiction and that Justice Valdez should have continued handling the case, including the motion for a new trial. Tagal refused to participate in the new trial, leading Judge Johnston to dismiss the case.

Tagal then filed this petition for mandamus, seeking to compel Judge Johnston to declare Justice Valdez’s judgment final and to annul all subsequent proceedings, or alternatively, to refer the motion for a new trial back to Justice Valdez.

ISSUE:
Whether Judge C.D. Johnston retained jurisdiction to act on the motion for a new trial and to dismiss the case after the expiration of the delegation period granted to Justice of the Peace Ramon Valdez.

RULING:
The Supreme Court DENIED the petition for mandamus.

The Court held that the delegation of jurisdiction to Justice Valdez was limited to the period specified by Judge Johnston. Once that period expired, jurisdiction automatically reverted to the CFI judge. There was no legal requirement that the delegated judge must continue to handle incidental matters, such as a motion for a new trial, after the delegation had ended. Judge Johnston, as the regular CFI judge, retained full jurisdiction to rule on the motion for a new trial, set the case for rehearing, and subsequently dismiss it when Tagal refused to proceed.

The Court emphasized that the delegation statute ( Act No. 2131 ) did not restrict the CFI judge from reassuming control after the delegation period. Since the defendants’ motion for a new trial was filed on time, the judgment of Justice Valdez had not become final. Therefore, Judge Johnston acted within his jurisdiction in granting the new trial and dismissing the case for Tagal’s failure to prosecute. Mandamus does not lie to control a judicial officer’s exercise of discretion within lawful authority.