All other Chief Justices, except for Victorino Mapa, were incumbent Associate Justices at the time of their appointment as Chief Justice. Mapa had served as Associate Justice from 1901 to 1913, when he was appointed as Secretary of Justice.
All other Chief Justices, except Victorino Mapa, were current Associate Justices at the time of their appointment as Chief Justice. Mapa had served as an Associate Justice from 1901 to 1913, when he was appointed as Secretary of Justice.